Now assume Zena acquired the stock of Delrey, Inc. and made a valid IRC Section 338(g) election.

On July 1, 2019 Zena, Inc. Purchased the stock ofDelrey, Inc. directly

fromDelrey's shareholders. Zena consummated the purchase using cash of $20,000,000 and property with an adjusted basis of $500,000 and a Fair Market value of $3,000,000. At the time of the acquisition,Delreyhad the following assets:

Assets	Adjusted basis	FMV
AR	400,000	300,000
Marketable securities	300,000	800,000
Loan receivable	200,000	100,000
US GOV Securities	500,000	500,000
Inventory	1,000,000	2,000,000
Furniture/fixtures	0	1,100,000
Building	600,000	4,000,000
Covenant not to compete	0	1,200,000
Total	3,000,000	10,000,000

Zena Inc. ultimately bears the burden of the corporate level tax on the deemed asset sale following a 338(g) election

True or False?