Mary and Jane, unrelated taxpayers, own Gray Corporation’s stock equally. One year before the complete liquidation
of Gray, in a §351 transaction, Mary transfers land (basis of $200,000, fair market value of $130,000) to Gray Corporation as a contribution to capital. In liquidation, Gray distributes the land to Jane. At the time of the liquidation, the land is worth $140,000. How much loss, if any, may Gray Corporation recognize on the distribution of the land to Jane?