LO$\mathrm{.}5$ Through an acquisitive $$Type D$$ reorganization, Border, Inc., is merged into Collie Corporation on September $2$ of the current calendar tax year. The Federal long$-$term tax$-$exempt rate for September is $3\%.$ Border shareholders receive $70\%$ of the Collie stock in exchange for all of their Border shares. Border liquidates immediately after the exchange. At the time of the merger, Border was worth $$1,000,000$ and held a $$500,000$ NOL.