Amy and Brian were investigating the acquisition of a tax accounting business, Bottom Line Incorporated (BLI). As part of their discussions with the sole shareholder of the corporation, Ernesto Young, they examined the company's tax accounting balance sheet. The relevant information is summarized as follows:

	FMV	Adjusted Tax Basis	Appreciation
Cash	$ 28,500	$ 28,500
Receivables	20,400	20,400
Building	127,000	63,500	63,500
Land	233,250	77,750	155,500
Total	$ 409,150	$ 190,150	$ 219,000
Payables	$ 24,200	$ 24,200
Mortgage*	174,800	174,800
Total	$ 199,000	$ 199,000

* The mortgage is attached to the building and land.

Ernesto was asking for $496,950 for the company. His tax basis in the BLI stock was $146,000. Included in the sales price was an unrecognized customer list valued at $189,000. The unallocated portion of the purchase price ($97,800) will be recorded as goodwill.

b. What amount of gain or loss does Ernesto recognize if the transaction is structured as a direct asset sale to Amy and Brian, and BLI distributes the after-tax proceeds [computed in part (a)] to Ernesto in liquidation of his stock?