I appreciate the advice but I think I have it covered. I have found "M&A Tax Report,
Vol. 11, No. 8, March 2003, Panel Publishers, New York, NY." that covers my situation. Admittedly it is from 2003 but I am going to rely on it. I am aware of related party and controlled corporation issues. A tax professional would cost me a significant part of what is involved and tax professionals do not always get it right. In fact the article that I have referred to says exactly that. The only way to be ok for sure is to have pre-approval from the IRS.
