On July 1, 2021, Tom and Jerry form TJ Smoothie Co., Inc. with Jerry contributing access to the commercial property rent free for 1 year and Tom contributing $50,000 in cash. Tom and Jerry each take 50 common shares in TJ Smoothie Co., Inc. By October 2021, the business is thriving, but Tom and Jerry are struggling to find reliable employees, so they ask Paula (Jerry's sister) to join the team. Paula also has an entrepreneurial bug, so she agrees to forgo salary for one year (but for a signing bonus of $1,000) in exchange for 50 common shares. She also has a several high-end blenders and furniture in her basement, so she also contributes those to TJ Smoothie Co, Inc., in exchange for the shares. In November, Tom, Jerry and Paula determine that they should open a second location. Tom asks his mother Mary for $25,000 in cash. On November 1, Mary agrees, but asks for 25 common shares in return. Tom, Jerry and Paula agree. Would there be a different result if all of the transactions were considered to be part of an integrated plan