Manufacturing

  

Manufacturing Corp. owns a five-acre parcel of land. Its factory takes up one acre of this land, and there is a mall on the other four acres. Manufacturing Corp. rents out retail space in the mall. To get rid of a troublemaker shareholder, Manufacturing Corp. wants to put all of the land into a subsidiary, sign a long-term lease for its own factory, and then split off this subsidiary by transferring it to the troublemaker shareholder in complete redemption of his stock. Discuss how this may or may not qualify as a divisive D reorganization followed by a sec. 355 distribution.