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PROBLEM Consider whether the following transactions qualify under Section 351 (a) A and B are unrelated individuals. A forms Newco, Inc. on January 2 of the current year by transferring a capital asset with a basis of $10,000 and a value of $50,000 for all 50 shares of Newco common stock. On March 2, in an unrelated transaction, B transfers a capital asset with a basis of $1,000 and a value of $10,000 for 10 shares of Newco nonvoting preferred stock (that is not nonqualified preferred stock). (b) Same as (a), above, except the transfers by A and B were part of a single integrated plan. (c) Same as (b), above, except A transferred 25 of her 50 shares to her daughter, D, as a gift on March 5 (three days after B's transfer). What if A's gift to D were on January 5? (d) Same as (b), above, except that two months after B's transfer, A sold 15 shares to E pursuant to a preexisting oral understanding, without which Newco would not have been formed. 2. TRANSFERS OF "PROPERTY AND STRYICTS