In which of the following independent situations is the Sec. 351 control requirement met?
a) Jane transfers property to Jet Corporation for 75% of Jet Corporation's stock, and Susan provides services to Jet Corporation for the remaining 25% of Jet Corporation stock.
b) Paul transfers property to Pride Corporation for 60% of Pride's stock, and Bob transfers property worth $15,000 and performs services worth $25,000 for the remaining 40% of Pride's stock.
c) Herb and his wife Carolyn each have owned 50% of the 100 outstanding shares of Wykert Corporation stock since it was formed three years ago. In the current year, their daughter, Cindy, transfers property to Wykert Corporation for 50 newly issued shares of Wykert stock.
d) John and Pam develop a plan to form PJ Corporation on May 2 of this year. John transfers property worth $50,000 for 50 shares of PJ Corporation stock. As part of the single plan to incorporate, Pam transfers $50,000 cash for 50 shares of PJ Corporation stock on July 1.
e) Assume the same facts as in Part (d), except that John has a prearranged plan to sell 30 of his shares to Steven on September 1.
a) Not met. Transferors of property receive only 75% and they do not have 80% control.
b) Met. Bob transferred more than a nominal amount of property. The 80% control test is met since all of Bob's stock is counted for this purpose.
c) Not met. Cindy owns only one-third of the stock immediately after the exchange. No attribution occurs from Cindy's parents to Cindy.
d) Met. John and Pam own 100% of PJ Corporation. The transfers do not have to be simultaneous.
e) Not met. John had a prearranged plan to sell a sufficient amount of shares to cause the control requirement not to be met.
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