When Tom passed away he owned an interest in Hill-dale Corporation which was included on his estate tax return. The IRS challenged the value of the Hill-dale stock arguing that the company possessed considerable goodwill. Therefore, the value should be adjusted upward. In disputing this contention, which of the following point(s) would be helpful to the estate in an attempt to decrease goodwill?

a) To provide financing, Hill-dale has been obtaining its working capital from the shareholders at a below-market rate of interest. 

b) The rate of return used by the IRS for the type of business involved is too high. 

c) Average net profit figures do not include large losses from unrelated investments. 

d) Tom was not an employee of Hill-dale but was merely a passive investor. 

e) None of the above.