TAXATION ‑- REAL ESTATE EXCISE TAX ‑- TRANSFER OF REAL PROPERTY ‑- TRANSFEROR CORPORATION OWNS ALL STOCK OF TRANSFEREE CORPORATION The one percent real estate excise tax does not apply to the transfer of real property by one corporation to another corporation where the transferor owns all of the authorized issued and outstanding capital stock of the transferee and no additional stock is to be issued in exchange for the real property.