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Cookie Monster owns a chicken named Pepe the Chicken (Pepe). Pepe the Chicken is a special chicken as it/she lays 50 eggs a day and

Cookie Monster owns a chicken named Pepe the Chicken ("Pepe"). Pepe the Chicken is a special chicken as it/she lays 50 eggs a day and each egg is perfect in size, shape and are the best tasting eggs in the world. Cookie Monster contributed Pepe the Chicken as property (assume that Pepe the Chicken is an ordinary asset and not a capital asset or a Section 1231 asset) as part of forming a new corporation named Monster Cookies, Inc., and the fair market value (FMV) of Pepe the Chicken is $100 and Cookie Monster's adjusted basis (AB) in Pepe the Chicken is $20. Assuming that all of the requirements of a Section 351 corporate formation are met, what would Cookie Monster's basis be in the shares that he receives as part of a Section 351 corporate formation? Please explain your answer.

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