C borrows $$250$ from bank on a non$-$recourse loan with property as security. C then transfers the property to Z Corporation, subject to the debt, in exchange for half of Z$\text{'}$s stock, and, as part of the same transaction, D transfers $$250$ in cash to Z in exchange for the other half of Z$\text{'}$s stock. Assume the property has a fair market value of $$500$ prior to the borrowing and a basis of $$200.$ Assume also that the borrowing does not have a tax avoidance purpose under $357($b$).$