Determine the tax consequences of this transaction to each of the two brothers.

The Jardhu family trust was established when the father transferred publicly traded securities with a cost of $120,000 and a fair market value of $250,000 into the trust. The beneficiaries of the trust are the father’s two sons, Sam, aged 25, and Mehrdad, aged 27. They have an equal interest in the income and capital of the trust. At the beginning of the current year, Mehrdad sells his capital interest in the trust to Sam. There have been no capital distributions from the trust. At the time of the sale, the fair market value of the securities in the trust is $380,000. Based on this, the transfer price for the capital interest is $190,000 [(1/2)($380,000)]. Determine the tax consequences of this transaction to each of the two brothers.

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