Question: In 2019, Mukesh and Michael each acquired 500 shares of ST Corporation in exchange for cash of $500. In 2020, ST needed additional funds and issued 100 shares of nonvoting preferred stock for $1,000 to a new investor. In 2021, Michael wants to transfer property with a value of 500 and a basis of 100 to ST for an additional 500 shares of common stock.
Describe the tax consequences of the transaction to Michael.
Cite authority for your answer.