Island tours has been an Exchange Act reporting company since going public three years ago. Island tours recently sold an additional 5 million of common stock through a regulation D private placement to several accredited investors. In the private placement, Skipper, the CEO purchased 100,000 shares at $10 per share and MaryAnn, an outside investor with no other affiliation with island tours, purchased 100,000 shares. Assume MaryAnn purchased her 100,000 shares from the private placement five months ago. Maryann gives the shares to her friend Gilligan to help him pay for repairs to his beach house. Gilligan sells the shares two months later,
