Sam owns 100% of M Corporation’s single class of stock. Sam transfers land and a building having a $30,000 and $100,000 adjusted basis, respectively, to M Corporation in exchange for additional M Corporation common stock worth $200,000 and IBM stock worth $20,000. The IBM stock had a $5,000 basis on M Corporation’s books. Peter transfers $50,000 in cash for 15% of the M Corporation common stock. What amount of gain or loss is recognized by Sam and M Corporation on the exchange?
Sam has come to you for advice so provide him with professional memo on the isssue, based on the IRC, treasury regulations, ruling and court cases if applicable.