Both Lupe and Rodrigo, father and son, own 50% of the stock outstanding of Heron Corporation (E & P of $400,000). During the current year, Heron redeems all of Lupes shares for $250,000. The transaction cannot qualify as a complete termination redemption if:

a.

Lupe received a $250,000 note receivable from Heron in the stock redemption.

b.

Lupe loaned Heron Corporation $50,000 two years following the redemption.

c.

Lupe continued to serve on Heron Corporations board of directors for two years following the redemption.

d.

Three years after the redemption, Lupe inherited Rodrigos shares in Heron as a result of his sons death.