HARRY W. KOCH, ALICE M. KOCH, and JOYCE M. MEEHAN, on behalf of themselves and all others similarly situated, Plaintiffs, v. FIRST UNION CORPORATION, FIRST UNION NATIONAL BANK OF DELAWARE, PENNSYLVANIA RESOURCE CORPORATION, FIRST LIBERTY FINANCIAL SERVICES, INC.,

with analysis and interpretation on how the case relates to section 351 of the Internal Revenue Code for essay please.

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