Corporation ABC Inc. has the following shareholders:

o John 50 shares of voting common stock

o Peter 25 shares of voting common stock

o Paul 15 shares of voting common stock

o Luke 10 shares of voting common stock

o Matthew 100 shares of non-voting convertible preferred stock (1 share of voting common for every 10 shares of preferred)

ABC makes the following distribution:

* John 100 shares of common voting

* Peter 50 shares of common voting

* Paul 30 shares of common voting

* Luke 20 shares of convertible non-voting preferred stock

* Matthew 10 shares of convertible preferred stock

The above distribution is taxable under Section 301 for who?