There is no answer. If they are capitalizing the corporation with cash, it simplifies things. If they are transferring in assets that have a low basis and they issue debt to themselves, they very well may have triggered taxable income.
Will they need to obtain additional financing? If so, banker would rather see paid-in capital even though they will require the stockholder debt to be subordinated.
Stockholders of S corporations are notorious for having short memories: They loan the company $10,000, pay themselves 3 checks of $5,000 each and will swear on a stack of Bibles that the company still owes them $5,000.
Another issue is stock basis. Usually companies lose money when they first begin operations. Repayment of debt that was included in basis for deducting losses will trigger taxable income.
Take a look at this link.
http://www.taxalmanac.org/index.php/Dis ... _of_s_corp
A pretty good rule of thumb is the 3:1 rule mentioned in the above article. If you have not had experience in this before, suggest you invest a little money with a really good tax practitioner and treat it as an educational as well as business investment.