June owned all the stock of Corporation A. Over the year, the corporation had been very successful but had never paid any dividends, although it had substantial earnings and profits. June wanted to expand into another line of business as a sole proprietor but did not have the cash to do so. June decided to form B, a new corporation. She contributed all the stock of A to B. B borrowed $100,000 from a bank using A stock as collateral. B then distributed all of its stock and the $100,000 to June. How should June treat the distribution of the stock and the $100,000?

AppendixLO1