the stock of emerald corporation is held equally by barney and faye the shareholders would like to receive as a dividend value of 800000 each/

Both assets are held as investments. Emerald Corporation has a capital loss carryover from the previous year of $80,000 and has accumulated E & P in excess of $2 million.
Barney and Faye have come to you for advice. Suggest an attractive tax plan to carry out what the parties want. Write a letter (addressed to Emerald Corporation at PO Box 940, Rochester, NY 14692) describing your plan and its tax consequences.