At the beginning of the current year, both Austin and Briana own $50\%$ of Apple Corporation. In July, Austin sold her stock to Tia for $$110,000.$ At the beginning of the year, Apple Corporation had accumulated E & P of $$200,000$ and its current E & P is $$250,000($prior to any distributions$).$ Apple distributed $$260,000$ on March $1($$$130,000$ to Austin and

$$130,000$ to Briana$)$ and distributed another $$260,000$ on October $1($$$130,000$ to Tia and $$130,000$ to Briana$).$ What are the tax implications of the $$130,000$ distribution to Tia?