YiLing, the sole shareholder of Brown Corporation, sold her Brown stock to Calvin on July 30 for $270,000. YiLing’s basis in the stock was $200,000 at the beginning of the year. Brown had accumulated E & P of $120,000 on January 1 and has current E & P of $240,000. During the year, Brown made the following distributions: $450,000 cash to YiLing on July 1 and $150,000 cash to Calvin on December 30. How will YiLing and Calvin be taxed on the distributions? How much gain will YiLing recognize on the sale of her stock to Calvin?