16. In 2019, Madison is considering making a proportionate non-liquidating distribution of shares of stock that it owns in CDE Corporation to its partners. Indicate the Internal Revenue Code section and subsection that describes how to determine the basis that the partners will have for the CDE stock that they receive. Enter your response in the answer fields below. Guidance on correctly structuring your response appears above and below the answer fields. Choose a title from the list. Select a title from the dropdown list below. Examples of correctly formatted IRC responses are IRC1(a), IRC12(a), IRC12A(a), IRC12AA(a), IRC123(a), IRC123A(a), IRC1234(a), IRC1234A(a), and IRC1234A-5(a)