One year after Sam and Jim form Small Corp, Tom would like to join the company as an owner. Before Tom joins, Sam owns 75% of the stock with a FMV of $750,000 and Jim 25% with a FMV of $250,000. Tom is going to contribute land with a FMV of 100,000 to the corporation in return for a 10% share in the company. (Reducing Sam to 70% and Jim to 20%)

How can Sam, Tom and Jim work together to ensure section 351 Treatment of Toms property contribution?