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Longhorn Company reports current E&P of $105,000 in 20X3 and accumulated E&P at the beginning of the year of negative $210,000. Longhorn distributed $315,000

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Longhorn Company reports current E&P of $105,000 in 20X3 and accumulated E&P at the beginning of the year of negative $210,000. Longhorn distributed $315,000 to its sole shareholder on January 1, 20X3. The shareholder's tax basis in his stock in Longhorn is $105,000. How is the distribution treated by the shareholder in 20X3?

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