Formal winding up required?

I have a client with share capital of £100k and he is now looking to wind up the company.

He has another accountant who has advised that if the company purchases £97k of its own shares (it has sufficient reserves to aviod a whitewash) and then does an ESC16 then this will get round the rules regarding share capital in excess of £4,000 going to the Treasury Solicitor.

I thought that the Capital Redemption Reserve is treated the same as the share capital and therefore this solution solves nothing.

Anybody got any views?
Colin Higginson