Hilton Corporation's Income Statement for the Year Ending December 31

Hilton Corporation's income statement for the year ending December 31, 2017, appears below.
$\begin{array}{lr}\text { Net sales } & \$ 810,000 \\\text { Cost of goods sold } & \underline{(610,000)} \\\text { Gross profit } & 200,000 \\\text { Selling and administrative expenses } & \underline{(90,000)} \\\text { Net operating income } & 110,000 \\\text { Gain on sale of land } & 112,000 \\\text { Interest expense } & \underline{(5,000)} \\\text { Income from continuing operations before tax } &{217,000}\\\text { Income tax expense } & \underline{(48,900)} \\\text { Net income } & \underline{\$ 168,100 }\end{array}$
Compute the maximum amount of dividends Hilton can pay if it has a debt covenant expressed as 20 percent of net income, and as 20 percent of net operating income. Which amount would a creditor more likely use as the restriction on dividends? Explain.