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Barry, Dan, and Edith together form a new corporation; Barry and
Dan each contribute property in exchange for stock. Within 2 weeks
after the formation, the corporation issues additional stock to
Edith in exchange for property. Barry and Dan each hold 10,000
shares and Edith will receive 9,000 shares. Which transactions will
qualify for nonrecognition?
A) Only the first transaction will qualify for
nonrecognition.
B) Only the second transaction will qualify for
nonrecognition.
C) Because of the step transaction doctrine neither transaction
will qualify.
D) Both transactions will qualify under Sec. 351 if they are
part of the same plan of incorporation.

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