On January 3, 2019, Adam, Brian, Charlie and Dave decide to form XYZ Corp. as a vehicle through which they intend to engage in a business.

Adam transfers machinery with a FMV of $90,000 and an adjusted basis in his hands of $105,000 to the corporation in exchange for 100 shares of voting common stock. The machinery was encumbered by a $70,000 liability at the time of the transfer.

Brian contributes a truck with a FMV of $20,000 and an adjusted basis of $8,500 in exchange for 100 shares of voting common stock.

Charlie transfers land with a FMV equal to $238,000 which is encumbered by a $218,000 liability and has an adjusted basis in his hands of $180,000 in exchange for 100 shares of voting common stock.

Dave receives 50 shares of stock in exchange for his agreement to render services for X Corp.

Does the incorporation of XYZ Corp qualify for treatment as a transfer to a controlled corporation?