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Alexandria and Penguin each own 50% of Pheasant Corporation, a calendar year taxpayer. Distributions from Pheasant are: $750,000 to Alexandria on April 1 and $250,000 to Penguin on May 1. Pheasant's current E & P is $300,000 and its accumulated E & P is $600,000. How much of the accumulated E & P is allocated to Penguin's distribution?

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