Mark owns 100% stock of Brand, Inc. His basis is the stock is $24,000. After several years of operation, Brand had $36,000 in accumulated E&P as of the start of the current year. During the current year, Brand had negative E&P of $32,000. On April 1 of the current year, 

Mark sold half of his Brand stock to George for $50,000. On December 31 of the current year, Brand distributed $20,000 in cash to Mark and $20,000 in cash to George. 

How will Mark treat the $20,000 distribution for tax purposes.