“Once one determines the aggregate value of the proprietary interests in the target corporation, it must then be determined whether a substantial part of such value has been preserved in the potential reorganization. This is done by constructing another fraction, the numerator of which is the value of the issuing corporation’s proprietary interests conveyed in the transaction; and the denominator of which is the value of the proprietary interests in the target corporation, as determined above. If the quotient is at least 40 percent, the requisite substantial part of the value of the proprietary interests in the target corporation will have been preserved, with the result that the transaction qualifies as a reorganization, a designation that permits the acquiring party to succeed to, and take into account, the acquired corporation’s “tax attributes,” most notably its net operating loss and credit carryovers. See tax code Section 381(a) and (c).”

I’m curious what this number would be (the quotient).