64. Zarco, a very profitable corporation, was owned by three shareholders, Julio, Tilly, and Martinez. Julio and Martinez purchased all of Tilly’s Zarco Corporation stock for $50,000 and a $100,000 promissory demand note that was guaranteed by Zarco. Tilly demanded payment on the note, and Zarco, rather than Julio and Martinez, paid the note. What are the tax consequences of this transaction?