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Two Individuals, Lionel and Merkin, were investigating the acquisition of a research business, the BLAND Corporation (a C corporation). As a part of their discussions

Two Individuals, Lionel and Merkin, were investigating the acquisition of a research business, the BLAND Corporation (a C corporation). As a part of their discussions with the sole shareholder of the corporation, Dr. Strangelove (an individual), they examined the company's tax accounting balance sheet. The relevant information is summarized as follows:

FMV

Cash 10,000

Receivables 15,000

Inventory 20,000

Building 100,000

Land 225,000

Total 370,000

Mortgage 112,000

Adjusted Basis

Cash 10,000

Receivables 15,000

Inventory 5,000

Building 50,000

Land 75,000

Total 155,000

Mortgage 112,000

Dr. Strangelove's tax basis in the BLAND stock is $100,000. Assume all corporations involved in this problem have lots of earnings and profits and have no NOL carryovers.

What amount of gain or loss does BLAND recognize if the transaction is structured as a direct asset sale to Lionel and Merkin, with Lionel and Merkin paying BLAND $400,000 in cash and assuming BLANDs $112,000 mortgage loan? [Note: Lionel and Merkin buy all of BLANDs assets (including the cash).]

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