Sheena owns 100% of Sheena Corporation. Sheena Corporation owns a painting by Monet of a haystack on a farm.Sheena Corporation paid 5 2 million dollars for the painting in1977. On 12/1/2024, the painting had a fair market value of $182million dollars.Dan owns 51% of Dan Corporation. Dan Corporation owns a painting by Renoir of a woman in a hat sipping wine at a bar.On 12/1/2024, Sheena Corporation exchanged its Monet for Dan Corporation's Renoir in an "even swap". Under IRC Section 1031, Sheena Corporation's realized gain will be $180 million dollars and recognized gain will be $0.