Yellow Corp., an S corporation, previously operated as a C corporation. At the time the S election was made (beginning of 2019), Yellow Corp. had accumulated earnings & profits of $20,000.

At the beginning of 2020, Yellow Corp. still had accumulated E&P of $20,000 and had an AAA balance of $100,000. During 2020, Yellow Corp. reported the following:

• Ordinary business income:                  $210,000
• Separately stated income items:         $10,000 (not tax-exempt income)
• Separately stated income items:         $5,000 (municipal bond interest – tax-exempt)
• Separately stated loss items:               $20,000

At the beginning of 2020, Sunny, the sole shareholder of Yellow Corp., had a stock basis of $150,000. During 2020, Yellow Corp. distributed $400,000 to Sunny.

a) What amount of the distribution is treated as dividend?

b) What amount of the distribution is treated as capital gain?