Acme Beverage Company transferred part of its assets to Lotus Technologies Corporation in exchange for all of Lotus’s stock. The transferred assets included its aluminum unit, which makes aluminum sheets; its paper packaging unit, which makes consumer-products packaging; and its ceramic unit, which makes high-technology ceramics used in computer boards and automotive parts. The Lotus stock received for the assets was distributed to the Acme shareholders. What tax issues should the parties to the divisive reorganization consider?