Consider whether the following transactions qualify under Internal Revenue Code Section 351:

(a) A and B are unrelated individuals. A forms Newco, Inc. on January 2 of the current year by transferring a capital asset with a basis of $10,000 and a value of $50,000 for all 50 shares of Newco common stock. On March 2, in an unrelated transaction, B transfers a capital asset with a basis of $1,000 and a value of $10,000 for 10 shares of Newco nonvoting preferred stock (that is not nonqualified preferred stock).

(b) Same as (a), above, except the transfers by A and B were part of a single integrated plan.

(c) Same as (b), above, except A transferred 25 of her 50 shares to her daughter, D as a gift on March 5 (three days after Bs transfer). What if As gift to D were on January 5?

(d) Same as (b), above, except that two months after Bs transfer, A sold 15 shares to E pursuant to a preexisting oral understanding, without which Newco would not have been formed.