In 2015, transportation equipment owned by Corporation ABC was stolen. The adjusted basis in the equipment was $105,000, and ABC received a $400,000 insurance reimbursement. It immediately paid $440,000 for replacement transportation equipment. On its 2015 tax return, ABC elected to defer the $295,000 gain realized on the involuntary conversion. In 2016, ABC generated a $7 million net operating loss— the first in its history. ABC’s aggregate taxable income on its 2014 and 2015 returns was $3.2 million.