Vincent E$.$ Oswald, $49$ T$.$C$.645(1968).$

Research Problem $2.$ Your client, White Corporation, has done well since its formation $20$ years ago. This year, it recognized a $$50,000,000$ capital gain from the sale of a subsidiary. White's CEO has contacted you to discuss a proposed transaction to reduce the tax on the capital gain. Under the proposal, White will purchase all of the common stock in Purple Corporation for $$200,000,000.$ Purple is a profitable corporation that has $$63,000,000$ in cash and marketable securities$,$ $$137,000,000$ in operating assets, and approximately $$280,000,000$ in E