Liam, a shareholder in Lager, Inc., (a C corporation), would like to sell 800 of his shares of stock in Lager. Since Lager is not traded on an exchange, the only way to sell is the stock is by having Lager redeem the stock. The fair market value of the 800 shares of stock is $200,000. Liam purchased the stock 10 years ago for $95/share. Lager has E&P of $700,000. The corporate stock in Lager is held as follows:

• Liam 2,000 shares
• Jennifer (Liams sister) 2,000 shares
• Katherine (Liams mother) 2,000 shares
• Beer Partnerships (Liam has a 30% interest) 4,000 shares 10,000 shares

How do you calculate the 800 shares of Liams stock to be treated as a qualified stock redemption or will it be treated as a distribution?