Mary and Jane unrelated taxpayers own Gray Corporation’s stock equally One year before the complete liquidation

Question

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?

a. $0

b. $60,000

c. $70,000

d. $200,000

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