Two unrelated individuals, John and Tom, own all the stock of Regal Corporation, which has earnings and profits of $400,000. Because of the inactivity of the business for the last several years, Tom has decided to retire from the business and move to Alaska. Accordingly, Regal Corporation will redeem all the stock owned by Tom and, in return, Tom will receive a distribution of $500,000. Tom's adjusted basis in the stock is $250,000. What will be the tax effect to Tom