Oscar and Felix together form the Odd Couple Corporation (Odd) on Jan. 1, 20x1. Oscar transfers equipment (basis of $575,000 and fair market value of $600,000) to Odd in exchange for 50% of Odds stock and $100,000 of cash from the corporation. Felix transfers cash of $110,000, investment land (basis of $598,000 and fair market value of $338,000) and agrees to provide ordinary and necessary cleaning services to the corporation in exchange for 50% of Odds stock. The services provided by Felix are worth $52,000. Assume that Odd began business immediately after it was incorporated and that Felix performed all of the required services between Jan. 2 and March 31. Answer the following:

A. Does Section 351 apply to the formation of Odd? Why or why not?

B. What is Oscars recognized gain/loss or income?

C. What is Felixs recognized gain/loss or income?

D. What is Oscars basis in the Odd stock?

E. What is Felixs basis in the Odd stock?

F. What basis does Odd have in the equipment (contributed by Oscar)?

G. What basis does Odd have in the land (contributed by Felix)?

H. What gain, loss, income or deduction does Odd recognize from these events? [Hint: See Section 83(h).]

I. How would you answer to Part H change (if at all) if the corporation still incorporated on Jan. 1 but did not begin business until April 1? If any of the corporations deductions changes, calculate the new deduction under these facts.