Sandra owned an equipment rental business in her sole name for four years. After her business advisors suggested that she conduct her equipment rental activity in corporate form, she promptly transferred the equipment to ABC Rental Corporation, a newly formed corporation. Sandra received all of the stock of ABC Rental Corporation in exchange for the equipment. At the time of the transfer of the equipment to ABC Rental Corporation, Sandra's adjusted basis in the equipment was $50,000, the fair market value of the building was $150,000, the equipment was subject to a security agreement and note assumed by the corporation of $70,000, and there was depreciation recapture potential of $12,000. Sandra received stock of ABC Rental Corporation worth $80,000. How much gain did Sandra recognize as a result of the transaction, and what was the character of the gain?