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QUESTION

Orange Corporation purchased bonds (basis of $350,000) of its wholly owned subsidiary, Green Corporation, at a discount.

Orange Corporation purchased bonds (basis of $350,000) of its wholly owned subsidiary, Green Corporation, at a discount. Upon liquidation of Green pursuant to section 332, Orange receives payment in the form of land worth $400,000, the face amount of the bonds. Green had a basis of $320,000 in the land. What are the tax consequences of this land transfer to Green Corporation and to Orange Corporation?

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