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Tornado Corporation transfers highly appreciated stock to Subsidiary Corporation in exchange for all of its stock. The Subsidiary Corporation then distributes the stock to

Tornado Corporation transfers highly appreciated stock to Subsidiary Corporation inexchange for all of its stock. The Subsid

Tornado Corporation transfers highly appreciated stock to Subsidiary Corporation in exchange for all of its stock. The Subsidiary Corporation then distributes the stock to its sole shareholder, Leonard. Three weeks after the distribution of the stock, Subsidiary Corporation liquidates. Leonard then sells the appreciated stock that he received in the liquidation. This series of transactions does not meet the statutory definition of a divisive Type D reorganization. fails the business purpose requirement. results in a capital gain to Patrick. None of the above is correct.

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