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Garnet Corporation has assets worth $700,000 with an adjusted basis of $315,000. Pearl Corporation would like to acquire all of Garnet's assets in a Type C reorganization in exchange for $450,000 of voting stock, $125,000 of cash, and assumption of Garnet's liabilities of $125,000. All stock received by Garnet will be distributed to its shareholders and Garnet will then liquidate.

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