I tried to think of the right answer. Unable to think of that, I spoke anyway.
"Uh, if a corporation distributes property and the fair market value exceeds the adjusted basis in the hands of the corporation, then the corporation will recognize a gain as if the property sold at fair market value."
I really probably should not have tried to do my tax homework during environmental law, huh?
No that is not a true story. Yes, that is I.R.C. S311(b)(1).
Per Grace: "I stole the first two sentences from Night of the Avenging Blowfish, by John Welter." If you're curious about this "Stolen Lines" business, check out Law With Grace.