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QUESTION 1 Alley, Bob, and Cain form ABC Corporation by transferring the following: From = Transferor Property Transferred Se
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No gain or loss shall be recognized if property is transferred to a corporation by one or more persons solely in exchange for stock in such corporation and immediately after the exchange such person or persons are in control as per sec 386(c)

Section 368(c) defines “control” to mean the ownership of stock possessing at least 80 percent of the total combined voting power of all classes of stock entitled to vote and at least 80 percent of the total number of shares of all other classes of stock of the corporation.

As none of them holds 80% of the total stock the transaction will not qualify for sec 351

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