on april 21 2011 crow corporation acquired land and equipment in a sect 351 transact 699176

On April 21, 2011, Crow Corporation acquired land and equipment in a § 351 transaction. At that time, the land had a basis of $300,000 and a fair market value of $225,000, and the equipment had a basis of $20,000 and a fair market value of $100,000. The land and equipment were transferred to Crow Corporation for use as security for a loan the corporation was in the process of obtaining from a local bank. The bank required the additional capital investment as a condition for making the loan. Crow Corporation adopted a plan of liquidation on October 3, 2012. On December 4, 2012, Crow Corporation distributes the land to Ali, a 40% shareholder. On the date of the distribution, the land had a fair market value of only $150,000. What amount of loss may Crow Corporation recognize on the distribution of the land?