Mark owns all the stock of Red and Green Corporations. Red has been reporting $125,000 in taxable income for each of the past five years. Green has been reporting $30,000 NOLs annually, which have accumulated to $150,000. Approximately one-third of Red’s profits come from sales to Green. Intercompany sales between Red and Green have increased during each of the last five years. What tax issues should Mark consider with respect to his investments in Red and Green Corporations?