Penguin Corporation purchased bonds (basis of $190,000) of its 100% owned subsidiary, Finch Corporation, at a discount. Pursuant to a § 332 liquidation and in satisfaction of the indebtedness, Finch distributes land worth $200,000 (basis of $160,000) to Penguin. Which of the following statements is correct with respect to the distribution of land?
a. Neither Finch nor Penguin recognize gain (or loss).
b. Finch recognizes no gain and Penguin recognizes a gain of $10,000.
c. Finch recognizes a gain of $40,000 and Penguin recognizes no gain.
d. Finch recognizes a gain of $40,000 and Penguin recognizes a gain of $10,000.
e. None of the above.
b
RATIONALE: Penguin recognizes a gain of $10,000 [$200,000 (value of land) – $190,000 (basis in bonds)]. Finch recognizes no gain or loss on distributions pursuant to a § 332 liquidation, even if property is transferred in satisfaction of indebtedness to Penguin.
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