Jennifer and Brad were engaged to be married. They entered into an ante-nuptial agreement pursuant to which they both surrendered any rights to alimony or a property settlement upon divorce. Pursuant to the agreement, on December 1, Jennifer transferred to Brad 100,000 shares of stock of Novio Corporation, which had a fair market value of $1,000,000 and for which she had paid $500,000. Two days later, they were married. What are the tax consequences?