Thank you for the opportunity to help you with your question!
Remember that Section 331
considers liquidating distribution to be a full payment of the shareholder’s
stocks in the corporation. In this regard, the shareholder will recognize a
gain or loss under Sec. 331. On the other hand, if the shareholder received
assets in exchange for her shares during the liquidation, and that these assets
are later for sale by the shareholder, then the shareholder’s gain or loss is
the difference between the asset’s fair market value at the liquidation and the
shareholder’s basis for her shares.
Please let me know if you need any clarification. I'm always happy to answer your questions.