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If A, a U.S. income tax nonresident alien, gifts U.S. real estate having a gross value of $900,000 and a basis of $320,000, which real

If A, a U.S. income tax nonresident alien, gifts U.S. real estate having a gross value of $900,000 and a basis of $320,000, which real estate is subject to a mortgage of $400,000, to R, his U.S. citizen cousin who assumes the mortgage, A will have IRC §897 gain of:

 

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$320,000

 

$ -0-

 

$400,000

 

$80,000

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