[murano]

It’s clear when a corp distributes property to its shareholders: corporate recognizes gain, adds it to current E&P, shareholders recognize a dividend income to the extent of E&P, excess amount is return of capital to the extent of his basis, and the remaining amount is capital gain.
Example: corp X distributes a land(fmv=20000,ab=15000)to A, X has no current&accumulated E&P, A has a stock basis of 3000. So in this case, X recognizes a gain=5000,adds it to its E&P, A recognizes dividend income to the extent of E&P=5000, the excess 15000 is a return of capital to the extent of A’s stock basis, and the remaining 12000 is a capital gain.
Howerver, another situation bothers me a lot:
During a corporation formation, how is the property given by corporation to its shareholders treated?
Say A contributed a Car (FMV=$20000,NBV=15000) and B contributed 10 motorcycles(each NBV=500) to form a C corp. They control 100%. The corp gave back A a motorcycle(FMV=1500).And this is at the formation.
A should treat it as boot received, and recognize the realized gain(which is 5000)to this extent(1500）
But How should the corporation treat this realized 500 gain? like a distribution(full recognition of 500),or just doesn’t recognize it,since it is given as a boot to get the property A contributes?