5. oberon and puck agree to establish oberon Spirits, Inc. ("osl"), to manufacture and sell fine wines and spirits. At the time of incorporation, two classes of stock are authorized: 1) voting common stock; and 2) 6% nonvoting preferred stock with a redemption feature mandating redemption of the shares at a specified premium 10 years from the date of issue. oberon contributes land for a winery with a basis of $75,000 and a fair market value of S500,000. Puck contributes a wine cellar already filled with fine wines he has collected over the years. Puck's basis for the wines and cellar was $20,000, and its fair market value at the time of contribution was $500,000. In return for his contribution, oberon receives 100 shares of common stock Puck, on the other hand, receives only 50 shares of common stock valued at $250,000 and osi securities bearing 8% interest payable over 10 years, also valued at $250,000. What are the tax consequences to Oberon, Puck, and the corporation