Individual A owns 50 common shares of X Corp. with an adjusted basis of 80,000. Individual B owns 50 X common shares with an adjusted basis of 120,000. X has accumulated earnings and profits of 50,000 and no results from operations for the current year. Before the transaction below, X has two assets, cash of 100,000 and land with an adjusted basis of 70,000 and a fair market value of 150,000.

X liquidates distributing its assets evenly between A and B. Assume that X pays any taxes it owes from the available cash and distributes the remaining cash.

What are all of the US tax consequences to all of the parties?