Early in $2018,$ a calendar$-$year corporation engages your services to prepare its federal income tax return for $2017.$ It informs you that it was created and capitalized in $($hopefully$)$ a section $351$ transaction employing only common stock. As you speak with the CFO, you learn the following with respect to the $4$ participating shareholders:

Shareholder #$1$ received $5\%$ of the stock in exchange for certain information in her custody related to the industry in which the corporation would be operating.

Shareholder #$2$ received $5\%$ of the stock in exchange for his provision of legal organizational services

Shareholder #$3$ received $30\%$ of the stock in exchange for raw land; $2/3$ of that stock was sold by shareholders #$3$ immediately after the attempted section $351$ transactions.

Shareholder $$3$ received $60\%$ of the stock in exchange for cash.

Consider only the section $351$ requirements of $$control$$ and $$property$$

Why may section $351$ treatment be in jeopardy? $($do not analyze the situation here; do so later; here only state the basic concern$($s$))$

To resolve this$/$these concerns$($s$),$ what questions do you need to ask with respect to :

Shareholder #$1$

Shareholder #$3$