Torres Corporation (a calendar year C Corp) has a positive accumulated E&P of $8,000 at the beginning of the year. During the year the Corporation incurs a current E&P deficit of $21,900. The corporation distributes $11,000 on March 16th ( 75th day of the year) to Ruben, it's sole shareholder, who has a $9,000 basis for the stock. How will Ruben treat the distribution for tax?