I have also tried 0 as an answer, as another expert answer came uo with, which was not correct.

Discussion Question 7-11 (10.5) Andy Co acquires DrewCo In a merger becoming AndrewCo. Andyco has $1,000,000 in positive accumulated E&P before the merger, and DrewCo has negative accumulated EP of $400,000 before the merger. AndrewCo wants to make a distribution to its shareholders after the end of its first year How much of the distribution is treated as a dividend Andrew Co expects to have minimal negative current E&P at the end of its first year? $ 400,000 X Feed The My World Some target corporation tax attributes (loss carryovers, tax credits, and E&P defides) are welcomed by the successor corporation. Others may prove less desirable (positive E & P and assumption of liabilities). The mandatory carryover rules should be carefully considered in every corporate acquisition; they may, in fact, determine the form of the transaction Discussion Question 7-11 (10.5) Andy Co acquires DrewCo In a merger becoming AndrewCo. Andyco has $1,000,000 in positive accumulated E&P before the merger, and DrewCo has negative accumulated EP of $400,000 before the merger. AndrewCo wants to make a distribution to its shareholders after the end of its first year How much of the distribution is treated as a dividend Andrew Co expects to have minimal negative current E&P at the end of its first year? $ 400,000 X Feed The My World Some target corporation tax attributes (loss carryovers, tax credits, and E&P defides) are welcomed by the successor corporation. Others may prove less desirable (positive E & P and assumption of liabilities). The mandatory carryover rules should be carefully considered in every corporate acquisition; they may, in fact, determine the form of the transaction