This year Sooner Company reports current E&P of negative $300,000. Its accumulated E&P at the beginng of the year was $215,000. Sooner distributed $400,000 to its sole shareholder, Boomer Wells on June 30 of this year. Boomer's tax basis in his Sooner stock is $75,000. How much of the $400,000 distribution is treated as a dividend to Boomer?