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Archer Corporation owns 100% of the stock of Connor Corporation. On July 1, 2023, Connor adopts a plan of complete liquidation and distributes the following

Archer Corporation owns 100% of the stock of Connor Corporation. On July 1, 2023, Connor adopts a plan of complete liquidation and distributes the following assets to Archer. Cash $100,000 Land Fair market value - 400,000 Basis - 500,000 Connor owes Archer 600,000 on the date of distribution. The loan was documented by a written promissory note and bears a market rate of interest. Connor has made all payments when due. Connor has a net operating loss carryforward of 200,000 from 2020. Archer's basis in its Connor stock is $700,000.

 What are the tax consequences of the distribution to Archer and Connor?

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