corporation is resisting the personal holding company tax, but the Tax Court sides with the IRS. Within 90 days after the adverse decision, one shareholder transfers his stock and $10,000 in cash to a controlled corporation in a Code Sec. 351 transaction, while another gifts his stock to an irrevocable trust with his minor children as beneficiaries.

Deficiency dividends are actually paid to the corporation and the trust. Are the shareholders able to shift the dividend income to the new entities?