if a redemption fails to qualify for sale treatment, the full amount received by the shareholder for the stock:

a. qualifies as a property distribution after deducting the stock's basis, and thus is a dividend to the extent of the corporation's yearly earnings.

b. qualifies as a property distribution and thus is a dividend to the extent of the corporation's E&P

c. qualifies for exchange treatment after deducting the stock's basis from the amount received.

d. qualifies for capital gain treatment.