Investor owns 1,000,000 shares of stock of Corp. XYZ with a zero basis and a FMV of 100,000,000 that the investor has held for 20 years. The investor sells 1,000,000 shares of XYZ short for $100,000,000 in February 2019. On January 21, 2020, the investor purchases 1,000,000 shares with a normal settlement for 120,000,000 and instructs the broker to deliver those shares to close the short sale. XYZ paid 4 dividends during 2019. The ex-dividend dates were March 1, June 1, September 1, and December 1. The total amounts of the dividends were $5,000,000. The investor did not borrow any money with respect to the transaction and because interest rates were so low did not receive any rebate on the short sale proceeds. What are the tax consequences in 2019 and 2020? Assume that closing the short sale on January 21 makes the constructive sale go away.