The stock of Cardinal Corporation is held as follows: 90% by Blue Jay Corporation (basis of $500,000) and 10% by Samuel (basis of $70,000) . Cardinal Corporation is liquidated on October 20, 2011, pursuant to a plan adopted on January 7, 2011. Pursuant to the liquidation, Cardinal Corporation distributed Asset A (basis of $450,000, fair market value of $720,000) to Blue Jay, and Asset B (basis of $45,000, fair market value of $80,000) to Samuel. No election is made under § 338. With respect to the liquidation of Cardinal:
A) Cardinal Corporation recognizes a gain of $35,000.
B) Blue Jay has a basis in Asset A of $720,000.
C) Samuel recognizes no gain (or loss) .
D) Blue Jay recognizes a gain of $220,000.
E) None of the above.
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