AndyCo acquires DrewCo in a merger, becoming AndrewCo. AndyCo has $1,000,000 in positive accumulated E & P before the merger, and DrewCo has negative accumulated E & P of $400,000 before the merger. AndrewCo wants to make a distribution to its shareholders after the end of its first year.

How much of the distribution is treated as a dividend if AndrewCo expects to have minimal negative current E & P at the end of its first year?