Twelve years ago, Mr$.$ Davis contributed a property that includes a building and land to Davis Office Furniture, a C corporation.

$$ The property will be used for office and warehouse space.

$$ Mr$.$ Davis acquired the property and used it as rental property for five years prior to the contribution to the corporation.

$$ The property was exchanged for a $30$ percent equity interest in the corporation.

$$ After the contribution of the property, Mr$.$ Davis had an $80\%$ interest in the corporation.

$$ The adjusted tax basis in the warehouse property at the time of the contribution to the corporation was $$1,500,000($building $$900,000$ and $$600,000$ land$).$ This basis reflects depreciation taken up to the date of the contribution.

$$ The building$$s appraised FMV on date of contribution to the business was $$1,650,000.$

$$

During the current year, Mr$.$ Davis decided to retire and close the business.

$$ On the last day of the year the corporation sold the property $($building and land$)$ to an unrelated purchaser for $$2,500,000.$

$$ A realtor was paid a $6$ percent commission.

$$ The corporation will liquidate its office furniture inventory shortly and the company may need your assistance with that at a later date.

Based on the facts above, did Mr$.$ Davis recognize a gain on the contribution of the property to the corporation? I know that according to IRC Section $351$ Mr$.$ Davis will not recognize a gain, are there any other IRC sections tat could be applied to this result. Thank you for your help,