Question $2(20$ points$)$ On July $1,2024,$ Adam, Brian, Charlie and Dave decide to form Newco Corp. as a vehicle through which they intend to engage in a business. Adam transfers machinery with a FMV of $$126,000$ and an adjusted basis in his hands of $$92,000$ to the corporation in exchange for $100$ shares of voting common stock. The machinery was encumbered by a $$86,000$ liability at the time of the transfer. Brian contributes a truck with a FMV of $$40,000$ and an adjusted basis of $$43,000$ in exchange for $100$ shares of voting common stock. Charlie transfers land with a FMV equal to $$229,000,$ which land is encumbered by a $$189,000$ liability and has an adjusted basis in his hands of $$178,000,$ in exchange for $100$ shares of voting common stock. Dave receives $60$ shares of stock in exchange for his agreement to render services for XYZ Corp valued at $$24,000.$ a$)$ Does the incorporation of XYZ Corp qualify for treatment as a transfer to a controlled corporation pursuant to section $351?$ Regardless of your answer to part a$),$ assume that the incorporation satisfies the requirement of section $351$ and will be treated as a transfer to a controlled corporation. b$)$ What is the amount of the realized gain or loss for Adam, Brian and Charlie? c$)$ What is the amount of gain or loss to be recognized by Adam, Brian and Charlie? d$)$ What is the amount and character of any income to be recognized by Dave? e$)$ What is the adjusted basis of the stock received from XYZ Corp. in the hands of Adam, Brian, Charlie and Dave? f$)$ What is XYZ Corp's adjusted basis in the machinery, the truck and the land it received from its shareholders?