A owns a Ferris wheel with a $$100,000$ adjusted basis $($AB$)$ and a fair market value $($FMM$)$ of $$975,000.$

B has $20$ shares of $3$ Flags Amusement Park FAP$).$

A agrees to exchange the Ferris wheel for $80$ shares in FAP that have a FMVV of $$972\mathrm{.}000,$ $$2,000$ in cash and costumes with a FMV of $$1,000.$

After the exchange, A is diagnosed with an illiness and decides to sell his stock and retireA sells the $80$ shares for $$972,000.$

A section $351$ transaction:

requires control of at least $60$ K of all classes the stock of the corporation and $40$ K of the total voting power of all classes of stock immediately after the exchange

requires control of at least $80\%$is of all classes the stock of the corroration and $808,$ of the total voting nower of all classes of stock within $12$ months of the exch onge

requires control of at least $805$ of all classes the stock of the corporation and $80\%$ of the total voting power of all classes of stock immediately after the exchange

has the advantage of flexibility in determining what constitutes control after the exchange based on the basis of property exchanged for stock

is not mandatory, so control is not an issue