$A,B,$&$C$ together form a new corporation. A & B each contribute property in exchange for stock. A & B each receive $50$ shares of stock

for their property. One month later, $C$ contributes other property to the corporation in exchange for $50$ shares of the corporation's

stock. Which transactions, if any, will qualify under IRC $351?$

A$.$ Both transactions will qualify under IRC $351$ if they are part of the same plan of corporate formation.

B$.$ Neither transaction qualifies under IRC $351$ because it violates the step$-$transaction doctrine.

C$.$ Only the first transaction qualifies under IRC $351$ because the second transaction does not satisfy the control requirement because $C$ alone only

owns $33\mathrm{.}33\%$ of the stock.

D$.$ Only the second transaction qualifies because the first translaction does not satisfy the control requirement because $A$&$B$ only own two thirds of

the total stock. The control requirement is not met until C is issued his stock.