Thanks Bob, for the input.  What I was looking for here was to see if there was some "loophole" with the in-kind distribution that might reduce or eliminate the tax obligation on the $110K distribution.  There aren't any.  You are right that the rollover option is long gone.  But, what I did learn from our discussion was that a direct rollover of in-kind assets is possible, without converting them to cash.

0 Cheers