Samual Rosen establishes a new corporation, arranging to have all of its common shares issued to his adult daughter for cash of $500. Mr. Rosen then transfers, using ITA 85, non-depreciable property with an adjusted cost base of $67,500 and a fair market value of $148,500. The transfer is made at an elected value of $67,500. As consideration for this property, the corporation gives Mr. Rosen a note for $67,500 and preferred stock with a fair market value and a legal stated capital of $20,250. Determine the amount to be included in Mr. Rosen's income as a result of the transfer.