On January 20^th, the Board of Directors of A Corp. declares a $5 per share cash dividend. The dividend is payable on January 30^th to shareholders of record on January 25^th. As of January 20^th, Taxpayer X owns 100 shares of A Corp.s stock. On January 23, Taxpayer X makes a gift of these 100 shares to Taxpayer Y. Which of the following correctly states case precedent in the Fifth Circuit Court of Appeals regarding the taxation of the cash dividends?

a. The Fifth Circuit Court of Appeals has held that Taxpayer Y reports the $500 cash dividend as taxable income because the fruit has sufficiently ripened as of the date of record.

b. The Fifth Circuit Court of Appeals has held that Taxpayer Y reports the $500 cash dividend as taxable income if Taxpayer Y is a qualified charity, or a family member of Taxpayer X, and the gift of the stock occurs after the declaration date but before the record date because gifts to charities and gifts to family members are treated differently by the Fifth Circuit Court of Appeals.

c. The Fifth Circuit Court of Appeals has held that Taxpayer X reports the dividend income as taxable income because the fruit has sufficiently ripened as of the date of dividend declaration.

d. The Fifth Circuit Court of Appeals has held that Taxpayer Y reports the $500 cash dividend as taxable income because the fruit has sufficiently ripened as of the date of declaration.

e. None of the other choices are correct.