Clarence Corporation is owned eighty percent $(80\%)$ by Curtis and twenty percent $(20\%)$ by Carl who are unrelated to each other. At the time of a Complete Liquidation, Clarence Corporation owned Land that had a Fair Market Value of $$300,000$ and a basis to Clarence Corporation of $$800,000.$ The Land was acquired by Clarence Corporation in a Section $351$ Transfer two $(2)$ years ago from Carl when its Fair Market Value was $$400,000.($Assume that there was no business purpose for the transfer$).$ Pursuant to the Complete Liquidation, the Land is sold to an unrelated third party for $$300,000$ and the $$300,000$ proceeds of the sale are distributed proportionately $($pro$-$rata$)$ to Curtis and Carl $($ie$.$ eighty percent $(80\%)$ to Curtis and twenty percent $(20\%)$ to Carl$).$ The Recognized Loss to Clarence Corporation is: