Question - Bart a 50% owner of Atlas Corp's common stock receives a distribution of a new class of Atlas preferred stock having a $40,000 FMV. Bart's basis in the Atlas common stock is $30,000. Its FMV is $80,000 on the distribution date. One year later, the corp. redeems the preferred stock for $75,000. At the time the stock was issued, the corp.'s current and accumulated E&P was $80,000. At the end of the year of redemption, the current and accumulated E&P is $25,000. No other distribution out of E&P were made in the year of redemption. What are the tax consequences of the transaction? How much will be taxed to the recipient as a dividend? How much is a return of capital? Is any of the distribution a capital gain?

Use no fewer than 3 citations to Substantial Authority to answer the question.