Hummingbird Corporation has 1,000 shares of common stock outstanding owned by unrelated parties as follows: Juan,300 shares,Erika,300 shares,and Dalissa,400 shares.Each of the three shareholders paid $75 per share for the Hummingbird stock 10 years ago.Hummingbird has $800,000 of accumulated E & P and $40,000 of current E & P.In January of the current year,Hummingbird distributes land held as an investment (adjusted basis of $260,000,fair market value of $220,000)to Dalissa in redemption of all 400 of her shares.In December of the current year,Hummingbird distributes securities held as an investment (adjusted basis of $90,000,fair market value of $110,000)to Erika in redemption of 200 of her shares.

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