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Owl Corporation acquired land in a 351 exchange one year ago. The land had a basis of $300,000 and a fair market value of $350,000

Owl Corporation acquired land in a 351 exchange one year ago. The land had a basis of $300,000 and a fair market value of $350,000 on the date of the transfer. Owl Corporation has two shareholders, Steve (80%) and Alice (20%), who are brother and sister. Owl Corporation adopts a plan of liquidation in the current year. On this date, the land has decreased in value to $250,000. Owl Corporation sells the land for $250,000 and distributes the proceeds pro rata to Steve and Alice. What amount of loss may Owl Corporation recognize on the sale of the land?

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