On July 1 2016 CNE Inc. Contributes real estate to a newly formed corporation NewCo Inc. The real estate has an adjusted basis to CNE of $236,000 and a FMV of $622,000 and was originally purchased in 1966. CNE Receives 200 shares of common stock with a FMV of $311,000 and 100 shares of non voting preferred stock with a FMV of $311,000. The stock received by CNE from NewCo represents all stock issued and outstanding. CNEs realized gain is equal to