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Skylark Corporation Owns 90% of the Outstanding Stock of Quail

question 47

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Skylark Corporation owns 90% of the outstanding stock of Quail Corporation,having purchased the stock five years ago for $550,000.Pursuant to a plan of liquidation adopted by Quail Corporation on March 4,2010,Quail distributes all its property on December 1,2010,to its shareholders.Quail Corporation had never been insolvent and had E & P of $830,000 on the date of liquidation.Pursuant to the liquidation,Quail distributed property worth $690,000 (basis $580,000) to Skylark Corporation.How much gain must the parties recognize in 2010 on the transfer of this property to Skylark Corporation?


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