Five years ago, Rachel transferred property she had used in her sole proprietorship to Green Corporation for 100 shares of Green Corporation in a transaction that qualified under 351. The assets had a tax basis to her of $200,000, and a fair market value of $350,000, on the date of the transfer. In the current year, Green Corporation (E&P of $1 million) redeems 30 shares from Rachel for $225,000 in a transaction that qualifies for sale or exchange treatment. With respect to the redemption, Rachel will have a