Frank and Sam (father and son) organize a corporation with 100 shares of common stock to...

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Frank and Sam (father and son) organize a corporation with 100 shares of common stock to which Frank transfers property worth

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Answer 1

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Yes Sec. 351 applies to this transaction.
Under IRC Section 351(a) a tax consequence can be deferred because no gain or loss is recognized (reported) provided:
ONLY STOCK is exchange for the property, and
You are in CONTROL of the corporation immediately after the exchange.

Both the conditions are fulfilled in case of Sam and Frank. So sec. 351 is applied here.

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Answer 2

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