In a qualified Sec 351 transaction, when Corp D was formed, it issued 100 shares of common voting stock with a total FMV of $400

Tom exchanged a patent ($50 basis; owned for 5 years) for 20 shares ($80 FMV) of R Corps common voting stock

Mary provided $100 worth of legal services to Corp D and transferred $200 cash in exchange for 80 shares ($320) of Corp Ds common voting stock($320 FMV). Marys income tax rate is 10%.

Under Sec 351, what are the tax consequences to Tom, Mary, and R Corp?