Problem:
Banbury Coporation offered to acquire the business operated by Luttrell Inc., in a type C reorganiztion. In addition to it business, Luttrell owns residential rental property ($420,000 FMV and $270,000 adjusted basis) that Banbury does not want. According to the reorganization plan, Banbury will issue voting stock in exchange for Luttrell's business assets and immediately after this exchange, Luttrell will liquidate by distributing the stock and rental property to its shareholders. The FMV of the distribution will exceed the Luttrell shareholders' aggregate basis in their stock by $2 million. What tax consequences result from the fact that Banbury is not acquiring the rental property in the type"C" reorganization?