After a complete liquidation has been adopted, Wren Corporation sells its only asset, unimproved land (basis of $600,000) held as an investment. The land is sold to Seth (an unrelated party) for $1 million. Under the terms of the sale, Wren Corporation receives cash of $100,000 and Seth’s notes for the balance of $900,000. The notes are payable over the succeeding 5 years ($180,000 per year) and carry an appropriate rate of interest. Immediately after the sale, Wren Corporation distributes the cash and notes to Adam, the sole shareholder of Wren. Adam has an adjusted basis of $400,000 in the Wren stock. The installment notes have a value equal to their face amount of $900,000.a.