Comet Company is owned equally by Pat and his sister Pam, each of whom hold 205 shares in the company. Pam wants to reduce her ownership in the company, and it was decided that the company will redeem 103 of her shares for $2,060 per share on December 31, 20X3. Pam's income tax basis in each share is $900. Comet has total E&P of $350,000. What are the tax consequences to Pam because of the stock redemption?