On September 30, Sinclair Corporation, a calendar year taxpayer, sold a parcel of land (basis of $600,000) for a $1,500,000 note. The note is payable in three installments, with the first payment due next year. Because Sinclair did not elect out of the installment method, none of the $900,000 gain is taxed this year. Sinclair Corporation had a $510,000 deficit in accumulated E & P at the beginning of the year. Before considering the effect of the land sale, Sinclair had a deficit balance in current E & P of $140,000.

Susan, the sole shareholder of Sinclair, has a basis of $400,000 in her stock. Susan holds the Sinclair Corporation stock as an investment. If Sinclair distributes $1,000,000 to Susan on December 31, how much income must she report for tax purposes?