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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 ยง 351? If not, why not? Show your work, or provide your rationale.

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