On April 7, 2010, Crow Corporation acquired land in a transaction that qualified under § 351. The land had a basis of $480,000 to the contributing shareholder and a fair market value of $350,000. Assume that the shareholder also transferred equipment (basis of $50,000, fair market value of $200,000) in the same § 351 exchange. Crow Corporation adopted a plan of liquidation on October 6, 2011. On December 8, 2011, Crow Corporation distributes the land to Ali, a shareholder who owns 20% of the stock in Crow Corporation. The land's fair market value was $300,000 on the date of the distribution to Ali. Crow Corporation acquired the land to use as security for a loan it had hoped to obtain from a local bank. In negotiating with the bank for a loan, the bank required the additional capital investment as a condition of its making a loan to Crow Corporation. How much loss can Crow Corporation recognize on the distribution of the land?
A) $0.
B) $50,000.
C) $180,000.
D) $230,000.
E) None of the above.
Correct Answer:
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