Allen contributes machinery and real property to Jack Corporation that has been in existence for several years as follows:

	Adjusted Basis	Fair Value
Machinery	100,000	150,000
Real Property	500,000	550,000

Jack Corporation has two classes of stockone with voting rights and one without voting rights. In exchange for the machinery and real property, Allen receives stock with a fair market value of $700,000. Immediately after the transfer, Allen owns 75% of the outstanding shares of corporate stock with voting power and 80% of the outstanding shares of each class of nonvoting stock of the corporation. How much gain or loss is recognized by Allen? Consider section 351 implications