Problem

Mary and Jane, unrelated taxpayers, hold Gray Corporation's stock equally. One year before the complete liquidation of Gray, Mary transfers land (basis of $600,000, fair market value of $180,000) 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 $150,000.

a. How much loss may Gray Corporation recognize on the distribution of the land to Jane?

b. Assume that the transfer of land to Gray Corporation was made so that the corporation could subdivide the land and build residential housing. However, a subsequent deterioration of the housing market forced Gray Corporation to abandon its plans. What amount of loss may Gray Corporation recognize on the distribution of the land to Jane?