George, an individual, is an architect and general contractor. Gracie is a wealthy individual. Newcos Certificate of Incorporation states that it is authorized to issue 200 shares, no par value of common stock. Gracie transfers $500,000 of cash to Newco in exchange for 50 shares of Newco's stock. George signs a contract with Newco in which George will perform services designing a housing project and then acting as general contractor on the construction of that housing project. In exchange, George will receive 50 shares of Newco's stock.

a. How will A be treated in this transaction?

b. Suppose instead that George and Newco do not enter into a written contract. George transfers $500 in cash for 50 shares of Newco's stock while Gracie transfers $500,000 for 50 shares of Newco's stock. George then performs the architectural and contracting services for no further charge. Would this change your answer