Individuals A and B are planning to form CORPORATION C, which will engage in manufacturing. A will
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Individuals A and B are planning to form CORPORATION C, which will engage in manufacturing. A will contribute to machinery and equipment with a fair marketvalue of $100M, and an adjusted basis of $45M. Y will contribute $100M of cash.CORPORATION C will issue to each of A and B, 100 shares of voting common stock inexchange for the property contributed. Consequently, there will be 200 commonshares outstanding with a total initial value of $200M. What are the tax consequencesto A, B, and CORPORATION C in this transaction? See §§ 351, 358, 362, 1001, 1032, and1223.
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