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Marmot Corporation pays a dividend of $100,000 in the current year. Otter Corporation, which is in the 25% marginal bracket, owns 15% of Marmot's stock. Gerald, an individual taxpayer in the 25% marginal bracket, also owns 15% of Marmot's stock.

Compare and contrast the treatment of the dividend by Otter Corpo- ration and Gerald.

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