Elk Company reports negative current E&P of $205,000 and positive accumulated E&P of $310,000. Elk distributed $210,000 to its sole shareholder, Barney Rubble, on December 31, 20X3. Barney's tax basis in his Elk stock is $78,750. What is the tax treatment of the distribution to Barney and what is his tax basis in Elk stock after the distribution