the gross income of such corporation), and (B) no gain or loss shall be recognized to such corporation upon the issuance of such stock. (2) Treatment limited to value of stock For purposes of this subsection, a contribution of money or other property to a corporation shall be treated as being in exchange for stock of such corporation only to the extent that the fair market value of such money and other property does not exceed the fair market value of such stock. (3) Application to entities other than corporations In the case of any entity other than a corporation, rules similar to the rules of paragraphs (1) and (2) shall apply in the case of any contribution of money or other property to such entity in exchange for any interest in such entity. (c) Treasury stock treated as stock Any reference in this section to stock shall be treated as including a reference to treasury stock. . (b) Basis of corporation in contributed property (1) Contributions to capital Subsection (c) of section 362 is amended to read as follows: (c) Contributions to capital If property other than money is transferred to a corporation as a contribution to the capital of such corporation (within the meaning of section 76) then the basis of such property shall be the greater of— (1) the basis determined in the hands of the transferor, increased by the amount of gain recognized to the transferor on such transfer, or (2) the amount included in gross income by such corporation under section 76 with respect to such contribution. . (2) Contributions in exchange for stock Paragraph (2) of section 362(a) is amended by striking contribution to capital and inserting contribution in exchange for stock of such corporation (determined under rules similar to the rules of paragraphs (2) and (3) of section 76(b)) . (c) Conforming amendments (1) Section 108(e) is amended by striking paragraph (6). (2) Part III of subchapter B of chapter 1 is amended by striking section 118 (and by striking the item relating to such section in the table of sections for such