Lilly Inc., a calendar year U.S. corporation, owns 40 percent of the stock of Holly, Inc. a calendar year specified foreign corporation. Prior to 2018, Holly has accumulated deferred foreign earnings of $11.2 million and an aggregate foreign cash position of $1.8 million. Compute Lilly's tax liability on its mandatory inclusion amount related to its ownership of Holly.

$412,400

$694,400

$1,031,000