Jade Corporation merged into Fluorite Corporation 2 years ago. At the time of the merger, Jade had an E & P deficit of $350,000 and Fluorite had a positive E & P of $300,000. The prior 2 years have resulted in a positive E & P of $100,000. Despite having a negative E & P of $30,000 for the year, Fluorite makes a distribution to its shareholders of $370,000. How is the distribution taxed to the shareholders ?