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Sam and Devon agree to go into business together selling college-licensed clothing. According to the agreement, Sam will contribute inventory valued at $146,000 in return

Sam and Devon agree to go into business together selling college-licensed clothing. According to the agreement, Sam will contribute inventory valued at $146,000 in return for 80 percent of the stock in the corporation. Sams tax basis in the inventory is $79,000. Devon will receive 20 percent of the stock in return for providing accounting services to the corporation (these qualify as organizational expenditures). The accounting services are valued at $36,500. (Negative amount should be indicated by a minus sign. Leave no answer blank. Enter zero if applicable.)

c. What amount of income, gain, or loss does Devon realize on the formation of the corporation? What amount, if any, does he recognize?

Income, gain or loss realized ?
Income, gain or loss recognized ?

My initial answer was $146,000 - $79,000 = $67,000 but this was marked incorrect. Please show all work explain how to get the answer.

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