Seven years ago, Eleanor transferred property she had used in her sole proprietorship to Blue Corporation for 2,000 shares of Blue Corporation in a transaction that qualified under 351. The assets had a tax basis to her of $400,000 and a fair market value of $700,000 on the date of the transfer. In the current year, Blue Corporation (E & P of $1,000,000) redeems 600 shares from Eleanor for $260,000 in a transaction that does not qualify for sale or exchange treatment.

With respect to the redemption, Eleanor will have a:

a.$140,000 capital gain.

b.$260,000 dividend.

c.$260,000 capital gain.

d.$140,000 dividend.