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Scott received only stock of Little Grove Corporation in exchange for $15,000 cash and business equipment valued at $55,000. Immediately following the exchange, Scott owned

Scott received only stock of Little Grove Corporation in exchange for $15,000 cash and business equipment valued at $55,000. Immediately following the exchange, Scott owned 81% of the total combined voting power of all classes of stock and 100% of all other classes of stock. Can Scott apply the general non-recognition provision of Section 351?

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