At the beginning of the current year, both Kelsey and Brysen own 50% of Apple Corporation. In July, Kelsey sold his stock to Audrey 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 Kelsey and

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