Last year, Boone decided to terminate the S corporation election of his solely owned corporation...

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Accounting

Last year, Boone decided to terminate the S corporation election of his solely owned corporation in preparation for taking the company public. At the time, the corporation had AAA of $200,000 and $450,000 of accumulated E&P from prior C corporation years. Boone had a basis in his S corporation stock of $200,000. During 2017, the firm reported $0 taxable income/loss and made distributions of $75,000 cash and $100,000 cash to Boone.
Boone terminated his S election effective September 30,2016. The distributions were paid on September 1st,2017 and September 16th,2017. The September 16th distribution was a property (non-cash) distribution (FMV and AB were both $100,000) rather than a cash distribution. How will the distributions be taxed (i.e. dividend, tax free return of capital, or capital gain)?

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