Parrot Corporation is a closely held company with accumulated E & P of $300,000 and current E & P of $350,000. Tom and Jerry are brothers; each owns a 50% share in Parrot, and they share management responsibilities equally. Parrot sells an office building (adjusted basis of $350,000; fair market value of $300,000) to Tom for $275,000. Which statement is incorrect?

a. The result of this transaction is a realized loss of $50,000.

b. Parrot recognize the realized loss of $50,000.

c. E & P is reduced by $75,00.

d. Tom has a constructive dividend of $25,000.

e. None of the choices.