Hawkeye Company reports current E&P of $300,000 this year and accumulated E&P at the beginning of the year of $200,000. Hawkeye distributed $400,000 to its sole shareholder, Ray Kinsella, on December 31 of this year. Rays tax basis in his Hawkeye stock before the distribution is $75,000.

How much of the $400,000 distribution is treated as a dividend to Ray?