On December $30,2020,$ Taxpayer T $("$T$")$ received $100$ shares of X Corporation stock from T$\text{'}$s employer as compensation for services provided.

As of that date. each X share had a fair market value $("$FMV$")$ of $$1\mathrm{.}000($i$.$e$.$

$$100\mathrm{.}000$ value in total$).$ On December $30.2021.$ each X share had a FMV of $$1,100$ per share. On December $30,2022,$ When each X share had a FMV of $$950$ per share. T gifted $50$ X shares to T$\text{'}$s son $("$S$").$ S combined the $100$ shares in a single account and could not distinguish which shares S received on any given date. On December $30.$

$2023,$ when each X share had a FMV of $$1,200$ T gifted the remaining $50$ shares to S$.$

a$.$ What income, gain or loss. if anv, would S recognize if S sold all $100$ shares of X stock for $$150,000$ on January $1,2024?$