Dick and Edward are equal partners in a partnership that operates a sporting goods store. The partnership bas two assets: (i) inventory with a tax basis of $500,000 and a value of $900,000 and (ii) goodwill with a tax basis of zero and a value of $3,100,000. Edward and Dick each have an outside basis of $250,000. Dick sells a 25% interest in the partnership to Lauren for $1,000,000. How much gain is recognized by Dick? What is the character of the gain?