Bruce is the sole owner of Wayne Enterprises, Inc., a calendar-year taxpayer. Wayne made one distribution during 2021 on April 1st in the amount of $1,000,000. At year-end, Wayne had a current E&P deficit of $500,000 and their accumulated E&P was $1,000,000. Bruces basis in his shares of Wayne was $800,000. What are the tax consequences?

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