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Julio owns 100% of stock of the C corporation The Perm Bank, Inc. (Perm). Perm has total E&P of $20,000 and Julio has a basis

Julio owns 100% of stock of the C corporation The Perm Bank, Inc. (Perm). Perm has total E&P of $20,000 and Julio has a basis of $100,000 in his Perm stock prior to the following distribution. Perm makes a nonliquidating distribution to Julio of land held for investment. The land has an $800,000 adjusted basis and a fair market value of $400,000 at the time of the distribution. 


What is Perm's recognized gain or loss on the distribution?

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