Red Corporation is owned eighty percent (80%) by Helen and twenty percent (20%) by Freddie who are unrelated to each other. Pursuant to a Complete Liquidation, Red Corporation distributed Land that had a Fair Market Value on the date of distribution of $100,000 and a basis to Red Corporation of $600,000. The Land was acquired by Red Corporation in a Section 351 transfer two (2) years ago from Freddie when its Fair Market Value was $200,000. (Assume that there was no business purpose for the transfer). What is the Recognized Loss for Red Corporation if the Land is distributed entirely to Freddie?