Based on Section 351, and the transactions between Sam and Devon, the following are true:
The income realized will be:
= 100,000 - 60,000
= $40,000
Section 351 will not recognize a gain or loss.
Based on the Carryover principle, Sam's basis in the inventory will remain the same at $60,000.
This will be the value of the accounting services of $25,000 because it is the fair value of the service.
This would be the income recognized of $25,000 which is what the accounting services are worth.
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