Derek, a cash basis, unmarried taxpayer, had $610 of state income tax withheld during 2019. Also in 2019, Derek paid $50 that was due when he filed his 2018 state income tax return and made estimated payments of $100 toward his 2019 state income tax liability. When Derek files his 2019 Federal income tax return in April 2020, he elects to take the standard deduction, which reduced his taxable income. As a result of overpaying his 2019 state income tax, Derek receives a refund of $435 early in 2020. How much of the $435 will Derek include in his 2020 gross income?