2. A, an individual, owns 100% of X Co. X owns 2 businesses, a widget business and a cog business. Both businesses have been actively conducted for 25 years. The widget business has assets with a FMV of 100, and no liabilities. The cog business has assets with a basis of 50 and a FMV of 200. The cog business also has liabilities of 100. X transfers the cog business to Newco in exchange for 100% of Newco stock.. X then distributes the Newco stock to A. Assume that A has a basis in X of 100. Assume that X has an NOL carryover of 100 expiring next year. Assume that the transaction is not a device.

What are all the consequences on all the parties?