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Five years ago, Eleanor transferred property she had used in her sole proprietorship to Blue Corporation for 100 shares of Blue Corporation in a transaction that qualified under § 351. The assets had a tax basis to her of $200,000, and a fair market value of $350,000, on the date of the transfer. In the current year, Blue Corporation (E & P of $1 million) redeems 30 shares from Eleanor for $225,000 in a transaction that qualifies for sale or exchange treatment. With respect to the redemption, Eleanor will have a _____.

a) $165,000 dividend

b) $165,000 capital gain

c) $225,000 dividend

d) $225,000 capital gain

e) None of the above

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