J owns all the stock of T. Ts only asset is a thoroughbred racing track with an adjusted basis of $1,200,000 and a fair market value of $3,000,000. Js basis in the T stock is $1,000,000. P, a corporate developer of shopping malls wants to acquire the race track for a mall site. P and J agree on a Type C reorganization, with T trading the race track for P stock worth $2,580,000 and $20,000 in cash and then liquidating. P will give T some treasury shares P bought in the market for $2,000,000. Assume this will qualify as a good Type C reorganization to which T and P are parties to a reorganization.

a. Upon Ts distribution of the P stock and cash to J, T recognizes no gain under Section 336(c) and Section 361(c).

b. Upon the distribution of the P stock and cash, T has recognized gain of $20,000 on the distribution of the boot.

c. Upon the distribution of the P stock and cash, T has gain of $2,580,000 less $1,200,000 less $20,000.

d. None of the above.