On April 1 of Year 1, Irvan, a U.S. corporation, acquired for $300,000 all the stock in DeLeon, a foreign corporation. At the close of business on September 30 of Year 3, Irvan sells the DeLeon stock for $825,000. Irvan reports $25,000 of Subpart F income as a result of DeLeon's activities in Years 1 through 3, none of which is a leap year. DeLeon reports E&P balances for the period as follows:

Year __________________ E&P

1 .......................... $120,000

2 .......................... 110,000

3 .......................... 144,000

What are the amount and character of Irvan's gain on the sale of the DeLeon stock? Can Irvan use any of DeLeon foreign taxes to reduce its U.S. tax liability on the stock gain?