Can you provide me with some similarities and differences between below two cases of law under section 351? Please do not just tell me the result of it, such as case 1 qualified section 351, and case 2 did not. Thank you. Case 1 Citation: Martin Ice Cream Co. v. Commissioner, 110 T.C. 189, 110 T.C. 18 (U.S.T.C. 1998) History: United State Tax Court, 1998 Citation: John P. and Alice Bongiovanni, Appellants, v. Commissioner of Internal Revenue, Appellee, 470 F.2d 921 (2d Cir. 1972) History: US Court of Appeals for the Second Circuit - 470 F.2d 921 (2d Cir. 1972)