Five shareholders each contribute $$10,000$ in exchange for a $20\%$ interest in FIU Corporation. Fifteen years later, FIU Corp. enters into a plan of complete liquidation. Under the plan, FIU Corporation distributes property with a fair market value of $$125,000$ and a basis of $$50,000,$ subject to a $$100,000$ mortgage, to the shareholders.

What are the tax consequences to FIU Corporation?

A$.$ The corporation will have a $$75,000$ loss

B$.$ The corporation will have a $$75,000$ gain

C$.$ The transaction will be treated under Section $336($a$)$ as if the property had been sold at FMV to the shareholders

D$.$ The amount realized by the corporation does not include the $$100,000$ mortgage

E$.$ B and C are correct