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Gavin contributes $ 5 0 0 , 0 0 0 of services to a C corporation in exchange for 7 5 % of the shares

Gavin contributes $500,000 of services to a C corporation in exchange for 75% of the shares outstanding. Which of the following statements best describes the tax treatment of this exchange?
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Gavin must recognize $500,000 of ordinary income because Sec. 351 does not apply.
Gavin must recognize $500,000 of income because he does not control the corporation immediately after the exchange.
Gavin need not recognize any income as long as another party transfers property in exchange for at least 5% of the shares outstanding.
Gavin need not recognize any income because the 80% threshold for control does not apply to services.

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