As far as the 80% is concerned, it relates to anyone who contributes property and cash. When I was studying for REG, the easiest way to remember this rule is that anyone who decides to contribute services in exchange of stock is a traitor and is trying hard to make the transaction taxable. funny, but it works.
Lets take this example
A (20% Owner) contributed services, B (65 % Owner) contributed property , C (10% Owner) contributed property, D (5% owner) contributed cash
A is the traitor here, but his actions will not cause the other shareholders to be taxed, simply because B,C and D have control (80%)
If D had contributed services other than cash, his action would have made the transaction a taxable even, because B & C does not have control (75%)
Hope this helps..
REG -63│ 84!!
BEC- 59│70│ 71 │78!
AUD- 75!
FAR- 87!
Mass-CPA