Jennifer owns land -Section 1231 property used in her sole proprietorship-- with a fair market value of $350,000. Her tax basis in this property is $80,000. Jennifer transfers this property to a newly-formed C Corporation for $200,000 worth of common stock and $150,000 of non-qualified preferred stock. Jennifer receives 100% of the common stock and 100% of the qualified preferred stock of the C Corporation.1) Write a short 2-sentence essay identifying the IRC Code Section involved and explaining whether or not this transaction will satisfy it to defer (in other words, not recognize) some or all of the realized gain (or loss) on the exchange.