Mary and Jane, unrelated taxpayers, hold Gray Corporation's stock equally.

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