Problem
As part of a Type A reorganization, Hall Corp. transferred property with a value of $15 million and a basis of $8 million, in exchange for $13 million worth of stock in Gate Corp. and $2 million worth of two-year Gate Corp. notes. Hall immediately distributed the Gate stock and Gate notes to its shareholders pursuant to the plan of reorganization. How much income must Hall Corp. recognize as a result of its distribution of the Gate stock and Gate notes to its shareholders?