On January 1 of the current year, Blackcat, Inc. has accumulated E & P of $174,000. Current E & P for the year is $540,000, earned evenly throughout the year. Beezlebub and Allegra are sole equal shareholders of Blackcat from January 1 to April 30. On May 1, Beezlebub sells all of his stock to Hades. Black cat makes two distributions to shareholders during the year: a total of $278,400 ($139,200 to Beezlebub and $139,200 to Allegra) on April 30 and a total of $487,600 ($243,800 to Allegra and $243,800 Hades) on December 31.