Longhorn Company reports current E&P of $$180,000$ in $203$ and a deficit of $($ $$360,000)$ in accumulated E&P at the beginning of the year. Longhorn distributed $$540,000$ to its sole shareholder on January $1,20$X$3.$ The shareholder's tax basis in his stock in Longhorn is $$180,000.$ How is the distribution treated by the shareholder in $203?$