As part of a Type A reorganization, Hall Corp. transferred property with a value of \(\$ 15\) million and a basis of \(\$ 8\) million, in exchange for \(\$ 13\) million worth of stock in Gate Corp. and \$2 million worth of twoyear Gate Corp. notes. Hall immediately distributed the Gate stock and Gate notes to its shareholders pursuant to the plan of reorganization. How much income must Hall Corp. recognize as a result of its distribution of the Gate stock and Gate notes to its shareholders?