Robin Corporation, a calendar year taxpayer, had a deficit in current E & P of $200,000 during 2018 and a $480,000 positive balance in accumulated E & P at the beginning of 2018. If Robin determined that a $700,000 distribution to its shareholders was appropriate at some point during 2018, what is the maximum amount of the distribution that could potentially be treated as a dividend?

a. $280,000 b. $380,000 c. $480,000 d. $580,000 e. $700,000