Lydia is a 30% partner in the JKL partnership. She has owned her partnership interest since the inception of the partnership and has never contributed appreciated assets to the partnership. Assume the partnership does not own any sec. 751 (ordinary income) assets. Lydia has an outside tax basis of $50,000 in JKL and the partnership interest has a fair market value of $1,000,000. The partnership wants to distribute $1,000,000 of cash to Lydia to redeem her partnership interest. Lydia directs the partnership, instead of distributing the cash, to use the $1,000,000 to buy a retirement home in the Cayman Islands. Two minutes after JKL purchases the home, JKL distributes the home to Lydia in complete redemption of her partnership interest. Will Lydia recognize any gain on the distribution in redemption of her partnership interest (briefly explain why or why not, with reference to how the Tax Court has addressed this type of transaction)?