Paul, single taxpayer, owns land that serves as security for a $100,000 loan he obtained from a local bank. The land was originally purchased several years ago for $65,000, which represents Pauls current tax basis in the land. Paul defaults on the bank loan and the bank forecloses on the land, taking legal title to it from Paul in 2020 in complete satisfaction of the outstanding amount of the bank loan. The FMV of the land at the time the bank foreclosed on it was $80,000. Pauls 2020 taxable income before consideration of this transaction was $60,000.

1. What would be the income tax implications in 2020 to Paul, including the character and tax rate imposed on any income or gain to Paul, as a result of the foreclosure proceeding if the bank loan was non-recourse in nature?
2. What would be the income tax implications in 2020 to Paul, including the character and tax rate imposed on any income or gain to Paul, as a result of the foreclosure proceeding if the bank loan was recourse in nature?