The stock in Black Corporation is held equally by two brothers. One year before its liquidation, the shareholders transfer property (basis $400,000, fair market value $450,000) to Black Corporation in return for stock in a Section 351 transaction. In a liquidation in the current year, Black Corporation transfers the property (now worth $100,000) pro rata to the brothers. What amount of loss will Black Corporation recognize on the distribution?

a. $0.

b. $20,000.

c. $300,000.

d. $320,000.