I:6-48 Constructive Ownership. PIB Partnership is owned 20% by Sara, 40% by Steve, and 40% by Thann. Burnham, Inc. is owned 70% by PIB Partnership, 10% by Ralph, 10% by Thann, and 10% by Sara. Ralph and Thann are brothers. All other individuals are unrelated.

During the current year, Ralph sold a piece of land to Burnham, Inc., for $90,000.

Ralph originally purchased the land as an investment a few years ago for $100,000.

a. How much of the loss may Ralph recognize?

b. Now assume all the same facts except that the sale occurred between Thann and Burnham, Inc. How much of the loss may Thann recognize?

c. Now assume the same facts as in b except that Burnham, Inc., is owned 60% by Sara and 40% by Ralph. Thann sells the land to Burnham, Inc. How much of the loss may Thann recognize?