No gain or loss is recognized on the transfer of assets from one corporation to another for stock or securities of the transferee corporation as long as the transferor owns 80% of the transferee's stock after the transaction.

• Create a scenario where the transfer of property to a controlled corporation under Section 351 of the Internal Revenue Code (IRC) results in taxation to the transferor.
• Speculate as to the reasons that gain treatment in the current year may be preferred to the deferral of gain.
• Provide a tax-planning strategy.