Sam and Devon agree to go into business together selling college-licensed clothing. According to the agreement, Sam will contribute inventory valued at $198,000 in return for 80 percent of the stock in the corporation. Sam's tax basis in the inventory is $117,000. 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 $49,500.

a. What amount of income, gain, or loss does Sam realize on the formation of the corporation? What amount, if any, does Sam recognize?

b. What is Sam's tax basis in the stock received in return for his contribution of property to the corporation?

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

d. What is Devon's tax basis in the stock received in return for the contribution of services to the corporation?

e. Assume Devon received 25 percent of the stock in the corporation in return for his services. What amount of gain or loss does Sam recognize on the formation of the corporation?