At the time of its liquidation under 332, Pink Corporation (earnings and profits of $560,000) had the following assets and liabilities: cash ($175,000); marketable securities (fair market value of $230,000, basis of $250,000); unimproved land (fair market value of $600,000, basis of $300,000); unsecured note payable ($50,000); and mortgage on the unimproved land ($270,000). Pink Corporation also had a net operating loss carryover of $45,000. Wren Corporation acquired all of the stock of Pink Corporation seven years ago for $160,000.

• How much gain (or loss) will Pink Corporation recognize upon the liquidating distribution of its assets and liabilities to Wren Corporation?
• How much gain (or loss) will Wren Corporation recognize in the liquidation of Pink?
• What basis will Wren have in the marketable securities and unimproved land it receives in the liquidation?
• What happen to Pink's earnings and profits and net operating loss carryover?