XYZ has been an S corporation since its inception six years ago. On January 1 of the current year, the corporation's two equal shareholders, John and Jane, had adjusted bases of $150,000 and $175,000, respectively, for their S corporation's stock. The shareholders plan to have the corporation distribute land with a $50,000 adjusted basis and a $200,000 FMV in the current year. Ordinary income is expected to be $180,000 in the current year. What tax issues should John and Jane consider with respect to the distribution?