Under Revenue Ruling 84-111, which option for transferring assets of a partnership to an S corporation?

A. The partnership must be dissolved and all assets liquidated before the S corporation is formed. This method is called "Assets out."

B. The partnership distributes the assets to the partners. The partners then contribute the assets to the corporation. This method is called "Assets up."

C. The partnership contributes the assets to the S corporation in exchange for shares. This method is called "Assets over."

D. All assets and liabilities are transferred to an qualified intermediary. The partnership interests are exchanged by the intermediary for shares in the S corporation in a tax- free exchange. This method is called "Interests over."