Lark Corporation is a calendar year taxpayer. At the beginning of the current year, Lark has accumulated E & P of $330,000. The corporation incurs a deficit in current E & P of $460,000 that accrues ratably throughout the year. On June 30, Lark distributes $200,000 to its sole shareholder, Adrienne. If Adrienne's stock has a basis of $40,000, how is she taxed on the distribution?