ELSA SA$,$ a Columbian Corporation, invested $$6,000,000$ in Dandys, Inc., a wholly$-$owned domestic C$-$Corporation. Dandys, Inc. acquired an apartment building in Chicago, Illinois, for $$2,000,000,$ purchased $$2,000,000$ of stock in small holdings of publicly$-$traded U$.$S$.$ corporations, and invested $$2,000,000$ in a fancy art gallery operated in rented space on Michigan Avenue that produced no U$.$S$.$ real property income. Although the art gallery has been subject to an annual lease with no right of renewal, it has operated at the same location since its establishment. After only five years, Dandys, Inc. is worth $$100,000,000$ and ELSA SA has decided to sell the company. Assume that the property values indicated in each case recited below represent the fair market value $($FMV$)$ of the assets on the date of sale and the relative FMV of the assets throughout the five$-$year period since Dandys, Inc. was organized. First determine if Dandys is considered a U$.$S$.$ Real Property Holding Corporation $($USRPHI$)$ then determine how much, if any, of ELSA S$.$A$.$s gain from the sale of the shares of Dandys will be subject to U$.$S$.$ income taxes if:

$($a$)$ The apartment building is worth $$60,000,000,$ the stock is worth $$20,000,000,$ and the art gallery assets are worth $$20,000,000.$

$($b$)$ The apartment building is worth $$40,000,000,$ the stock is worth $$20,000,000,$ and the art gallery assets are worth $$40,000,000.$

$($c$)$ The apartment building is worth $$30,000,000,$ the stock is worth $$30,000,000,$ and the art gallery assets are worth $$40,000,000$