Peach Tree Corp. has accumulated earnings and profits (E&P) of $280,000 and no current E&P for the current year. On December 31st Peach Tree Corp. distributes to Grape, its sole shareholder a parcel of land with a basis of $260,000 and a fair market value of $200,000. Grapes basis in the stock is $100,000. Grape plans on growing fruit trees on this land. What portion of the distribution to Grape will be treated as a dividend? Note: do not adjust earnings and profits for the tax effect of any gains or losses due to the distribution.