Michelle owns appreciated property and she wants to use this property to start a business with her son, Lance. Michelle is considering making a contribution of the property to a newly organized corporation in exchange for 100 percent of the corporate stock. She then contemplates giving half of the stock to Lance in exchange for his promise to manage the business. Do you think this transaction will qualify for 351 treatment? Suppose Michelle promises that she wont transfer the stock for a month after making the contribution of property. Does this make any difference? Compare Rev. Rul. 54-96, 1954-1 CB 111 with Intermountain Lumber Co., 65 TC 1025 (1976).