Nice, Inc., a § 501(c)(3) organization, inherited 100% of the stock of Aggressive, Inc., a for-profit entity, at the beginning of the year. Although Nice plans on selling the stock of Aggressive, a buyer has not yet been located. Aggressive's taxable income for the year is $900,000. Aggressive distributed a dividend of $525,000 to Nice at the beginning of December. Determine the tax consequences for the taxable income and the dividend payment:

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