corporate liquidations(taxation)

Except as otherwise provided, assume the following facts: X is a corporation engaged in the business of drying fruits. X has assets consisting of land, a drying shed and equipment. X's adjusted basis in the assets is 200. The FMV of the assets is 300. X has earnings and profits of 100. A, an individual, owns 100% (100 shares) of X . A's basis in his shares is 100

X Co. owns 100% of T Co. P Co. owns 100% of S Co. Both groups are affiliated groups which file consolidated tax returns. X has a NOL carryover of 100. P has a NOL carryover of 100. T and S have no NOL's. T has assets which consist of equipment with a FMV of 100, a cost basis of 75 and an adjusted basis of 50. P purchases 100% of X's T stock for 90 cash in one transaction. Assume X had a basis of 80 in its T stock.

What consequences if s.338 is elected?

Is there any further election which could change this result?