At the beginning of the year, Myrna Corporation (a calendar year taxpayer) holds E&P of $124,700. The corporation generates no additional E&P during the year. On December 31 the corporation distributes $187,050 to its sole shareholders, Abby whose stock basis is $37,410. How does the Federal income tax law treat this distribution? As a result the distribution Abby has the following Dividend income? Return of capital? Capital gain?