Miley will contribute $1,000,000 cash to the venture and McLovin will contribute a building that has a $1,000,000 fair market value and adjusted basis of $400,000. Initially Miley thinks she wants to pay McLovins $500,000 for a 50% interest in the building so she owns half of the building before they form the corporation. A) Walk them through a sec. 351 incorporation and how they might provide a better tax result.