Kesha, a sole proprietor, is engaged in a cash basis service business. In the current year, she incorporates the business to form Kiwi Corporation. She transfers assets with the basis of $500,000 (fair market value of $1.2 million), a bank loan of $450,000 (which Kiwi assumes), and $80,000 in trade payables in return for all of Kiwis stock. What are the tax consequences of the incorporation of the business?