PLEASE ANSWER IN TAX MEMO FORM

Donald Trump Corporation is currently owned by three individuals, Trump, Bush, and Clinton. The corporation has a net worth of $750,000 and has 500 shares (1,000 shares authorized) of common stock outstanding.

Trump owns 200 shares (40 percent), and Bush and Clinton each own 150 shares (30 percent).

Bernie Sanders owns land worth $90,000 which the corporation could use as a new plant site. Bernies tax basis in the land is only $20,000. Bernie is not interested in selling the land because it would result in a large capital gain tax. Bernie is willing to transfer the land to the corporation in exchange for 60 shares of its common stock or securities of equivalent value, but only if the transfer will be nontaxable. Question: How would you advise the parties to structure the transaction? At a minimum, you should cite the following sources: Rev. Rul. 73-472, 1973-2 C.B. 115. Rev. Proc. 76-22, 1976-1 C. B. 562. Reg. 1.351-1(a)(1)(ii).