Pink Corporation acquired land and securities in a 351 tax-free exchange. On the date of the transfer, the land had a basis of $720,000 and a fair market value of $630,000, and the securities had a basis of $110,000 and a fair market value of $250,000. Pink Corporation has two shareholders, Maria and Paul, who are unrelated. Maria owns 85% of the stock in the corporation, and Paul owns 15%. Pink adopts a plan of liquidation in the current year. On the date of the liquidation, the land's fair market value has decreased to $500,000. What is the effect of each of the following on the corporation?

Corporation cannot rebut the two-year presumption rule, $ of loss would be recognized. If Pink Corporation can rebut the presumption of a tax avoidance purpose for the transfer, $ of loss would be recognized

. If the land is distributed 50% to Maria and 50% to Paul, $ of the loss would be disallowed.