In January 2023, OWL Corporation ("OWL") acquired GATOR Corporation ("GATOR"). Both corporations are C Corporations. OWL pays GATOR shareholders one million shares of OWL voting stock, with a FMV of $10/share. GATOR is owned by five unrelated shareholders. Shareholders A, B, C, and D each own 10,000 shares of GATOR. Shareholders A, B, C and D exchange 10,000 shares of their GATOR voting stock to OWL. The 40,000 shares exchanged represents 90% stock ownership of GATOR. The remaining 10% of GATOR shares are owned by Albert who retained his GATOR shares and did not participate in the transaction. Each GATOR shareholder has a basis in their stock of $100/share and each shareholder has owned the GATOR stock for two years prior to the exchange. The transaction is for a valid business purpose. GATOR continues to operate its business after the transaction. What are the income tax consequences (gain/loss/character/basis) of the exchange to GATOR Shareholder A?