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Jen and Colleen form Jen Co. in 2016. Jen contributed services worth $24,000 and property worth $16,000, and Colleen contributed property worth...

Jen and Colleen form Jen Co. in 2016. Jen contributed services worth $24,000 and property worth $16,000, and Colleen contributed property worth $25,000. Jen received 44 shares, and Colleen received 25 shares of Jen Co. Is the transaction nontaxable under IRC § 351? If not, why not? Show your work, or provide your rationale.

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