Under what circumstances does property received by a corporation in a 351 transaction not receive a carryover

Question:

Under what circumstances does property received by a in a §351 transaction not receive a carryover basis? What is the reason for this rule?
Corporation
A Corporation is a legal form of business that is separate from its owner. In other words, a corporation is a business or organization formed by a group of people, and its right and liabilities separate from those of the individuals involved. It may...