Too many colors.

Steve Orange owns 100% of the stock of Purple Corp. and Fred Smith owns 100% of the stock of Red Corp. that, in turn, owns 100% of the stock of Blue Corp. Blue Corp. intends to acquire 100% of the stock of Purple Corp. from Steve in exchange for Red Corp. stock. Each of the following is a party to the reorganization as defined in §368, EXCEPT:

Purple

Orange

Red

Blue

Accountants are so clever :)