Sam and Devon agree to go into business together selling college-licensed clothing. According to the agreement, Sam will contribute inventory valued at $178,000 in return for 80 percent of the stock in the corporation. Sam's tax basis in the inventory is $98,000. Devon will receive 20 percent of the stock in return for providing accounting services to the corporation (these qualify as organizational expenditures). The accounting services are valued at $44,500. Assume Devon received 25 percent of the stock in the corporation in return for his services.