Tangerine Corporation is considering a property distribution to its shareholders. If appreciated property is to be used, does it matter to Tangerine whether the property distributed is a long-term capital asset or property subject to depreciation recapture? Would your answer differ if the property distributed has a fair market value less than the adjusted basis? Explain.

What advice would you give to the corporation when it wants to distribute out property that has a higher adjusted basis then its FMV?