sentences:  Under Internal Revenue Code section 368(a)(1)(A), this transaction could be largely tax-free if the former subsidiary is considered the "buyer" of the target company.The former subsidiary is the "buyer" if its shareholders (also the original parent company's shareholders) own more than 50% of the merged company.The original Morris Trust structure was the result of a favorable ruling by the United States Court of Appeals for the Fourth Circuit in 1966 in the case of "Commissioner v. Mary Archer W. Morris Trust".