Cook's Outlet has been an S corporation since its inception six years ago. On January 1 of the current year, the corporation's two equal shareholders, Davis and Dane, had adjusted bases of $150,000 and $175,000 respectively, for their S corporation's stock. The shareholders plan to have the corporation distribute land with a $50,000 adjusted basis and a $200,000 FMV in the current year. Ordinary income is expected to be $180,000 in the current year.
What tax issues should Davis and Dane consider with respect to the distribution? Include discussion of gain/loss at the corporate level, determination of shareholder basis before and after the distribution, realization of income by shareholders (if any), and holding period and basis for land received as part of the distribution.