Please do not copy paste others' answers here. Use the assumptions to answer this question.

On June 1, 2020, Hattie and Kitty formed Cat Corporation (a new entity).
Kitty contributed manufacturing equipment with a fair market value
of $150,000 and a basis of $100,000 in return for a 50% interest in Cat
Corporation. The equipment was secured by loan for $50,000 - which
was assumed by Cat Corporation. She took out the loan on
May 20, 2020. She purchased the equipment on January 1, 2017.
Hattie contributed a patent for cat toy manufacturing in return for
a 50% interest in Cat Corporation. Hattie purchased the patent on March 1, 2018
for $50,000.
a)	Does this transaction qualify for non-recognition treatment under IRC Sect. 351?
	Why or why not? Explain your answer fully.
b)	What are the tax consequences to Hattie as a result of this transaction?
c)	What are the tax consequences to Kitty as a result of this transaction?
d)	What are the tax consequences to Cat Corporation as a result of this transaction?
e)	Would you answer to a) change if Hattie had developed know-how for the equipment
	that she contributed (unpatented) specifically for Cat Corporation? If so, why?
f)	Would your answer to Part c) change if the loan was taken out to purchase
	the equipment back in 2017? If so why? And If so, how?

Assumptions:
Use a flat corporate tax rate of 21% for all problems. For individuals assume a tax rate of 15% for all dividends and capital gains.
Assume there is no Alternative Minimum Tax for these problems.
Assume that all entities are US domestic corporations, taxed under Subchapter C of the IRC unless otherwise noted.
the internal revenue code.