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Five years ago,Eleanor transferred property she had used in her sole proprietorship to Blue Corporation for 1,000 shares of Blue Corporation in a transaction that qualified under § 351.The assets had a tax basis to her of $300,000 and a fair market value of $450,000 on the date of the transfer.In the current year,Blue Corporation (E & P of $600,000) redeems 200 shares from Eleanor for $190,000 in a transaction that does not qualify for sale or exchange treatment.With respect to the redemption,Eleanor will have a:
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