Two unrelated individuals, dave and tom, own all the stock of arnold corporation, which has earnings and profits of $400,000. because of his inactivity in the business for the last several years, dave has decided to retire from the business completely and move to oregon. accordingly, arnold corporation will redeem all the stock owned by dave and, in return, dave will receive a distribution of $500,000. dave's adjusted basis in the stock is $250,000. what will be the tax effect to dave?