Malik owns appreciated property and wants to use this property to start a business with Lance. Malik is considering making a contribution of the property to a newly organized corporation in exchange for 100 percent of the corporate stock. Malik then plans to give half of the stock to Lance in exchange for managing the business. Do you think this transaction will qualify for $351 treatment? Does it make any difference if Lance is Malik's son? Suppose Malik promises that the stock transfer won't occur for a month after making the contribution of property. Does this make any difference? Consider Rev. Rul. 54-96, and Intermountain Lumber Co. 65 TC 1025 (1976).