Francis exchanges her 20% interest in Beryl Corporation for 10,000 shares of Pyrite Corporation (value $200,000) and $40,000 cash. Francis's basis in her Beryl stock is $95,000. The accumulated earnings of Beryl are $325,000, and the accumulated earnings of Pyrite are $225,000 at the time of the reorganization. How does Francis treat this transaction for tax purposes?