List the key statutory requirements that must be met before a corporate formation is tax-deferred under §351. In addition, what is the definition of control for purposes of §351? Why does Congress require the shareholders to control a corporation to receive tax deferral?

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List the key statutory requirements that must be met before a corporate formation is tax-deferred under §351. In addition, what is the definition of control for purposes of §351? Why does Congress require the shareholders to control a corporation to receive tax deferral? Under what conditions is it advantageous for a shareholder to hold §1244 stock? Why did Congress bestow these tax benefits on holders of such stock?

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