In the current year, Orion Corporation (E & P of $2 million) distributes all of its property in a complete liquidation. Allie, a shareholder, receives land having a fair market value of $300,000. Orion Corporation had purchased the land as an investment three years ago for $250,000, and the land was distributed subject to a $100,000 liability. Allie took the land subject to the $100,000 liability. What is Allie's basis in the land