Shepherd Corporation is considering acquiring RentCo by exchanging its stock (value of $10 per share) for RentCo's only asset, a tract of land (adjusted basis of $150,000 and no liability). The yearly net rent that RentCo receives on the land is $50,000. Shepherd anticipates that it will receive the same net rent for the land over the next 20 years. At the end of that time, it would sell the land for $400,000.

What is the maximum number of shares that RentCo shareholders can expect Shepherd to offer for 100% of their RentCo stock? Assume that Shepard uses a 10% discount rate and is in the 34% tax bracket for all years. What type of reorganization is this contemplated transaction? Hint: Use text Appendix F in your analysis.