Owl Corporation makes a nonliquidating distribution of property having a $50,000 adjusted basis and a $100,000 FMV to its sole shareholder, Brownie. Owl has current and accumulated E&P of $150,000. The property distributed is subject to a $40,000 mortgage, which Brownie assumes. Brownies basis in his Owl stock at the time of the distribution is $20,000. What are the income tax consequences to Brownie and to Owl Corporation of the distribution (gain, loss, basis, E&P)