Peach Tree Corp. has no accumulated or current earnings and profits through December 31st of the current year. On December 31st Peach Tree Corp. distributes to Grape, its sole shareholder a parcel of land with a basis of $1,395,000 and a fair market value of $2,945,000, subject to a mortgage of $2,170,000, which Grape assumed. Grape's basis in the stock is $775,000. 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. O $1,550,000 $2,945,000 $2,170,000 O $775,000