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No, so sorry. This would be disallowed (recharacterized and taxed either as an asset sale or stock sale) under the related party rules.
(IRC § 267) - Related Party Definitions and Attribution Rules
A “related party” is defined in Code Sec. 267 as including family members, a taxpayer and a corporation controlled directly or indirectly (through attribution from other family member stock holdings) by the taxpayer (more than 50% of the value of the stock), and a partner and a controlled (directly or indirectly) partnership. Sec. 267 also specifies other related parties, including a trust and its grantor, a trust and its beneficiary, and a personal services company and any shareholder-employee.
Further, in determining if a corporation and a shareholder are related parties, a series of constructive ownership rules specified in Sec. 267(c) are applied. In effect, these rules equate control with ownership, in that stock held by certain related parties is treated as though it is held by the taxpayer. The same is true of two corporations controlled, directly or indirectly, by the same person. Any transaction between a personal services corporation and an employee owner are automatically classified as related parties (regardless of the ownership percentage of the employee owner).
As an aside that's not UNrelated,
One of the primary reasons that Form 8594 is required in the asset sale is to ensure that the assets are classified an a uniform manner by both buyer and seller - (ensuring that where the buyer gets the step-up, the seller has the ordinary income tax)
ANd in the stock sale where the seller gets capital gain treatment, there IS no step up for the person stepping into the shoes as the new stockholder of the corporation.
This is not unrelated to the related party rules. One party or the other (to oversimplify a bit) must realize the tax that's commensurate with the type of sale.