Pursuant to a complete liquidation in the current year, Oriole Corporation distributes to Samantha land held for four years as an investment (basis of $225,000), fair market balue of $480,000). The land is subject to a liability of $150,000. Samantha, who owned 20% of the Oriole shares outstanding had a basis of $90,000 in the stock. What are the tax consequences of the liquidating distribution to Oriole Corporation and to Samantha?