Modern Corp. is a C Corporation electric vehicle startup with a single shareholder, Joe, who owns 10 shares of stock representing 100% of the outstanding shares. After two years of operation Joe realizes they need a factory building to begin construction, and additional cash capital. They develop a business plan in which Sam will contribute his factory worth 3 million dollars (adjusted basis= 1 million) for 30 shares of the corporation, and George will buy 70 additional shares for 7 million dollars cash. Pursuant to the plan Sam transfers his factory to Modern and receives his 30 shares on November 1, 2021, and George transfers 7 million of cash in return for his 70 shares on January 23, 2022. Please state, clearly and succinctly, the tax effect to Sam, if any, of these transactions. Also, determine if it would make any difference if, as part of the plan, Joe acquired one additional share for $100,000 cash at the time of Sams transfer of his factory to Modern? Base your advice solely on Federal tax law without regard to state tax consequences.