Tax Research Assignment $2$

For IRC $351$

a$)$ Cite the section where control is defined.

b$)$ Define control.

c$)$ Where is related party defined? Cite

d$)$ Define related party

For the following scenario, reference the following tax sources for your answer

IRC $351$

Treas. Reg. $1\mathrm{.}351-1$

Rev. Rul. $79-194$

Rev. Proc. $77-37$

Scenario

Bob and Carl transfer property to Stone Corp. for $90\%$ and $10\%$ of Stone stock respectively. Pursuant to a binding agreement concluded before the transfer, Bob sells half of his stock to Carl. Write an email to your tax manager explaining why the exchange does or does not meet the IRC $$351$ requirement.