3 page memo need in 6 hours

Jerome Howard exchanges property with a basis of $300,000 and a fair market value of $900,000 for 70% of the stock of Stooges Corporation.  The other 30% of the stock is owned by Jules White who acquired his stock several years ago.

You are a CPA in private practice and Jerome comes to you and asks you whether he must report a gain on the transfer on his tax return.

Please draft a letter to your client Jerome and an associated memo to the tax files with documentation for your response.

Your memo to the files should incorporate the following sections:

FACTS

ISSUES

LAW & ANALYSIS

CONCLUSION

I have attached an example.....