2. All of the outstanding stock of X Corporation is owned by Ivan (80 shares) and Flo (20 shares). X has no liabilities. Ivan contributed Gainacre ($100,000 adjusted basis, $400,000 fair market value) and Lossacre ($800,000 adjusted basis, $400,000 fair market value) to X. Flo contributed $200,000 cash. Assume Lossacre is $ 336(d)(1) "disqualified property" and $362(e)(2) applied to Ivan's contribution, but $ 336(d)(2) does not apply because there was no "plan" for X to recognize loss on that property. (a) What result if pursuant to a plan of liquidation X distributes each of its assets to Ivan and Flo in proportion to their respective stock interests? (b) Same as (a), above, except assume that $ 362(e)(2) applies to Ivan's contributions to X and $ 336(a)(2) applies to Lossacre because there was a "plan" by X to recognize loss in that property