El Toro Corporation declared a common stock distribution to all shareholders of record on June $30,20$X$3.$ Shareholders will receive one share of El Toro stock for each two shares of stock they already own. Raoul owns $460$ shares of El Toro stock, with a tax basis of $$99$ per share. The fair market value of the El Toro stock was $$139$ per share on June $30,20$X$3.$ What are the tax consequences of the stock distribution to Raoul?