John and Kevin are incorporating a business where John receives $20,000 in stock without recognizing gain, while Kevin, who transfers $80,000 in assets, must recognize gain due to lack of control. Alan, Bruce, and Connie are combining property into a corporation, but Section 351 will not apply since the transfers were part of a prearranged plan and the shareholders did not maintain control. Therefore, Section 351 only applies when shareholders work collectively to meet the control requirements.