Rosie, the sole shareholder of Eagle Corporation, has a stock basis of $100,000 at the beginning of the year. On July 1, she sells all of her stock to Manuel for $500,000. On January 1, Eagle has accumulated E & P of $45,000 and during the year, current E & P of $80,000. Eagle makes the following cash distributions: $90,000 to Rosie on March 31 and $90,000 to Manuel on November 1. How are the distributions taxed to Rosie and Manuel? What is Rosie’s recognized gain on the sale to Manuel?