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Silver Corporation redeems all of Alluvia s 3,000 shares and distributes to her 1,000 shares of Gold Corporation stock plus $20,000 cash. Alluvia s basis in her 30% interest in Silver is $80,000 and the stock s market value is $120,000. At the time Silver is acquired by Gold, the accumulated earnings and profits of Silver are $100,000 and Gold s are $50,000. How does Alluvia treat this transaction for tax purposes?