Corporation Z is owned entirely by two individuals, C and D. C owns 60 shares of Z common stock bought in one transaction for $1,200. D owns 40 shares of Z common stock with a basis of $60 per share. The stocks fair market value is $40 per share. Zs E&P is $1,000. C sells 60 shares to Z for $1,800. Additionally, C and D for this question are father and son.

Group of answer choices

a. There will be attribution under Section 318, so that no matter how many shares C sells to Corporation Z, by attribution he will own 100% of the outstanding shares afterwards.

b. There will be attribution under 318 if C's father is living since there is double attribution through C's father.

c. There is no attribution.

d. None of the above.