For example, if the whole target is represented by the fungus family and the bull's eye by mushrooms, a vague thought which can only hit the target as
a whole is not much use from a culinary point of view.
Proponents of this theory adopted a "two transaction" approach that views Parent's acquisition of an equity interest in Target as a separate transaction from the subsequent exchange of stock for the subsidiary.
Parent should account for Subsidiary's transfer to Target as a purchase of Target under Opinion no.
338(h)(10) election ignores the stock sale; rather, it treats the target as
though it first sold all of its assets, then liquidated under Sec.