Question: Alec, who is 77 years old, owns 20 percent of CandaceCo's stock, which is highly appreciated. Alec does not want to sell. The remaining 80 percent of CandaceCo's stock is publicly held. Barbara wants to acquire at least 80 percent of CandaceCo's stock for cash but knows it cannot get that much stock in a tender offer. How can Alec and Barbara use § 351 to cash out the public and satisfy Alec's desires? From a tax standpoint, what's the probable reason that Alec would not want to sell?