Your clients, Chris and Tina Cobb, have operated as a partnership for many years. They have approached you for tax advice on incorporating their business. Chris will contribute $50,000 cash in exchange for 50 shares of stock in the new corporation. Tina will contribute the land which has an adjusted basis of $35,000 and a fair market value of $50,000 for 50 shares of stock. For additional capital, the new corporation will borrow money from a bank and will then sell the land. Prepare a memo for Chris and Tina discussing the tax treatment of the transaction involved with forming the corporation. Include documentation and support for your advice, including code and regulations sections or any court cases that support your recommendation.