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?