Where a parent corporation sells depreciable property to a wholly-owned subsidiary under a sales agreement, the depreciable property is transferred back to the parent on default by the subsidiary at a time that the property has a UCC of $100,000 and a fair market value of $50,000, and the debt owing by the subsidiary of $80,000 to the parent is extinguished by a quit claim deed, s. 80 will apply to the amount of $80,000 owing by the subsidiary to the parent.