On May 1 of the current year, Kiara, Victor, Pam, and Joe form Newco Corporation with the following contributions in return for common stock: Transferor Asset transferred to Newco Basis to Transferor FMV Number of common shares issued Kiara Land $50,000 $100,000 400 Mortgage on land 60,000 Victor Inventory $25,000 $40,000 300 Pam Van $15,000 $10,000 50 Joe Accounting Services -0- $10,000 100 Kiara purchased the land several years ago for $50,000. Victor also received a Newco Corporation note worth $10,000 due in three years. The note bears interest at a rate acceptable to the IRS. Pam also receives $5,000 cash. Pam purchased the van two years ago for $20,000. Please write a detailed memo to the Newco Corp that addresses the following questions and explains your answers for each part. a. Does the transaction satisfy the requirements of Sec. 351 for a tax-free incorporation?