Martin owns 1,000 shares of stock in Black Corporation and 500 shares of stock in Blue Corporation, representing 100% ownership of Black and 50% ownership of Blue. Martin sells 200 Blue shares to Black Corporation for $300,000. Martin purchased the Blue stock four years ago at a cost of $600 per share. What are the tax consequences of the sale assuming that Black Corporation has E & P of $800,000 and Blue Corporation has E & P of $1 million?