Peach Tree Corp. has no accumulated or current earnings and profits through December $31$st of the current year. On December $31$st Peach Tree Corp. distributes to Grape, its sole shareholder a parcel of land with a basis of $$1,485,000$ and a fair market value of $$3,135,000,$ subject to a mortgage of $$2,310,000,$ which Grape assumed. Grape's basis in the stock is $$825,000.$ 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.

$$ $$1,650,000$

$$2,310,000$

$$825,000$

$$ $$3,135,000$