half moon corporation made a distribution of 300000 to Arnold Swartz in partial liquidation of the company on December 31, 20x3. Arnold owns 100 percent of the half-moon corporation (12000 shares). the distribution was in exchange for 50 percent of Arnold's stock in the company ( 600 shares). at the time of the distribution, the shares had a fair market value of 500 per share. arnold 's income tax basis in the shares was 250 per share. half mon had a total E&P OF 2000000 at the time of the distribution. what is the amount and character ( capital gain or dividend) of any income or gain recognized by Arnold as a result of the partial liquidation?