Aggie Corporation made a distribution of $547,000 to Rusty Cedar in partial liquidation of the company on December 31 of this year. Rusty, an individual, owns 100 percent of Aggie Corporation. The distribution was in exchange for 50 percent of Rustys stock in the company. At the time of the distribution, the shares had a fair market value of $193 per share. Rustys income tax basis in the shares was $48 per share. Aggie had total E&P of $8,445,000 at the time of the distribution.

a. What is the amount and character (capital gain or dividend) of any income or gain recognized by Rusty as a result of the partial liquidation?