F&D Incorporated ceased operations and dissolved under state law in 2020. Mrs. Herron, a 20% shareholder, received a $490,300 liquidating distribution from F&D. This year, the IRS determined that F&D underpaid its 2019 and 2020 income tax by $967,100. How much of this deficiency can the IRS assess against Mrs. Herron? $490,300 $193,420 -0- $967,100