65. Ken sold a rental property for $500,000. He received $100,000 in the current year and $100,000 each year for the next four years. Of the sales price, $400,000 was allocated to the building and the remaining $100,000 was allocated to the land.

Ken purchased the property several years ago for $300,000.

When he initially purchased the property, he allocated the land. Ken has claimed $25,000 of depreciation deductions over the years against the building. Ken had no other sales of §1231 or capital assets in the current year. For the year of the sale, determine Ken’s recognized gain or loss and the character of Ken’s gain, and calculate Ken’s tax due because of the sale (assuming his marginal ordinary tax rate is 32 percent). (Hint: See the examples in Reg. §1.453-12.)