Last year, Boone decided to terminate the S corporation election of his solely owned corporation in preparation for taking the company public. At the time, the corporation had AAA of $$200,000$ and $$450,000$ of accumulated E&P from prior C corporation years. Boone had a basis in his S corporation stock of $$200,000.$ During $2017,$ the firm reported $$0$ taxable income$/$loss and made distributions of $$75,000$ cash and $$100,000$ cash to Boone.

Boone terminated his S election effective September $30,2016.$ The distributions were paid on September $1$st$,2017$ and September $16$th$,2017.$ The September $16$th distribution was a property $($non$-$cash$)$ distribution $($FMV and AB were both $$100,000)$ rather than a cash distribution. How will the distributions be taxed $($i$.$e$.$ dividend, tax free return of capital, or capital gain$)?$