Sean and John form Willow Corporation. Sean transfers inventory (basis of $60,000 and FMV of $110,000) for 50% of the stock in Willow. John transfers machinery (basis of $20,000 and FMV of $60,000) and agrees to serve as manager of Willow Corporation for one year for 50% of the stock. Johns management services are worth $50,000. What are the tax consequences to John?