for the purchaser of an incorporated business, the advantage of a making a section 338 election or a 336(e) is:

A) A stock purchase transaction is treated for federal income tax purposes as a taxable purchase of the target company's assets, with the resulting basis step-ups for appreciated assets.

B) The IRS seldom audits business purchase transactions when these elections are made.

C) An asset purchase transaction is treated for federal income tax purposes as a taxable purchase of the target company's stock.

D) The purchaser can immediately expense the cost of all the target company's tangible and intangible assets.