In 2014, an industrial plant owned by Company C, a

In 2014, an industrial plant owned by Company C, a calendar year taxpayer, was destroyed in a flood. C’s adjusted basis in the plant was $1.65 million, and the company received a $2 million insurance reimbursement. On its 2014 tax return, C elected to defer the gain realized on the involuntary conversion. C promptly began construction of a new plant on the site of the old. However, because of unexpected delays, construction was not completed until January 2017, and C did not place the new industrial plant into service until March 2017. The total construction price was $3 million.