351 applies to whether a transferor has a continuing relationship with the property transferred to a corporation sufficient to justify non-recognition treatment or whether the transferor has severed the relationship with the transferred property, justifying recognition. Since Section 351 is not elective, it only applies when the taxpayer-transferor does the following: Question 2Answer a. receives bonds in exchange b. controls the corporation immediately after the exchange c. receives stock in exchange d. transfers property to a corporation