Consider whether the following transactions qualify under Section 351:

(a) Amanda and Barry are unrelated individuals. Allen 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, Barry 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 Allen and Barry were part of a single integrated plan.

(c) Same as (b), above, except Amanda transferred 25 of her 50 shares to her daughter Diana, as a gift on March 5 (3 days after Barrys transfer). What if Amandas gift to Diana were on January 5?

(d) Same as (b), above, except that 2 months after Barrys transfer, Amanda sold 15 shares to Emily pursuant to a pre-existing oral understanding, without which Newco would not have been formed.