A liquidated corporation will always recognize gain in a complete liquidation.
Gain realized is not recognized if the distribution is to a corporate shareholder and is tax deferred under section 332.

Question

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If the distribution is to a corporate shareholder in a complete liquidation, the gain realized may be tax deferred under section 332, and therefore not recognized. However, this is not always the case as there may be certain circumstances where gain is recognized in a complete liquidation even for a corporate shareholder.

A Liquidated Corporation Will Always Recognize Gain in a Complete