sentences:  This provision imposes additional taxation on the distribution in the spin-off step whenever a 50% interest in a spun off company is transferred tax-free in the two years following a spin-off.Verizon wished to sell its access lines to FairPoint Communications, Inc. Rather than simply selling these assets to Fairpoint, however, Verizon created a subsidiary to which it sold these assets.Verizon distributed the shares of this new subsidiary to Verizon's shareholders.