Wood Corporation is owned equally by two individuals—Allan and Baker.

Wood Corporation has two operating divisions, Oak and Pine, that have been conducting business for more than five years. Allan and Baker can no longer agree on the management of Wood Corporation's activities and decide to separate. Baker agrees to a plan whereby the assets of the Pine division worth $800,000 (adjusted basis of

$300,000) and liabilities of $100,000 will be transferred to newly formed Nuwood Corporation in exchange for all of Nuwood’s stock. The Nuwood stock (having a value of

$700,000) will then be distributed to Baker in exchange for all of his Wood Corporation stock having a basis of $200,000.

a. Will the plan qualify as a corporate reorganization? What type?

b. What would be the amount of Wood Corporation's recognized gain on the transfer of the Pine division assets to Nuwood? On the distribution of the Nuwood stock to Baker?

c. What would be the amount and character of Baker's recognized gain on the receipt of the Nuwood stock?

d. What is the basis of Baker’s Nuwood stock?