Jeff contributes cash of $1,000,000 to Fluffy Pillow Corporation in return for 50% of the stock. Mark contributes an asset with a FMV of $800,000 and tax basis of $400,000 plus $200,000 in services for 50% of Fluffy Pillow stock. Assuming the transaction qualifies under IRC Section 351, what is Mark's tax basis in the Fluffy Pillow stock he receives in the transfer?