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 adj. basis, $400,000 FMV) and Lossacre ($800,000 adj. basis, $$400,000 FMV) to X. Flo contributed $200,000 cash. Assume Lossacre is 336(d)(1) property and 362(e)(2) applied to Ivans 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) except assume that 362(e)(2) applies to Ivans contributions to X and 336(d)(2) applies to Lossacre because there was a plan by X to recognize loss in that property.