The stock in Brighton Corporation is held by two unrelated individuals, Martha (60%) and Charles (40%). One year before the liquidation of Brighton, the shareholders transfer properties to the corporation in a transaction that qualifies under § 351. Included in that transfer was land (basis of $400,000, fair market value of $450,000). Pursuant to its liquidation in the current year, Brighton Corporation distributes the land (now worth $300,000) pro rata to the shareholders.  What amount of loss will Brighton recognize on the distribution?