Cynthia is a successful sculptor who created

a work that is now worth $400,000 and has no tax basis.

Cynthia forms a corporation and contributes the sculpture to

it in exchange for the corporations shares. Fourteen months

later, she sells all the stock for $400,000. She wants to treat

the sale of the stock as a long-term capital gain. Evaluate the

Country of taxation USA

propriety of Cynthias actions

Please explain in details.