Representation of a New Jersey direct mail and fulfillment company in the negotiation and sale of assets to a Fortune 100 company in a tax-free reorganization: The sale was made after distribution to the seller's shareholders of over $1 million in retained earnings and in time for the buyer's ex-dividend date, adding $3 million to the seller's value. The buyer's stock received in sale by the seller's shareholders was transferable from inception. Anticipating a transaction, the seller's stock was moved among family members a year earlier, saving the family tens of millions of dollars in estate taxes.