Which of the following is NOT a correct statement of policy justifying why IRC 351 is in the tax code? Group of answer choices A. Without IRC 351, taxpayers who contribute appreciated property to a corporation in exchange for stock in a controlled corporation would immediately recognize a taxable gain between the fair market value of the stock received and the taxpayer's adjusted basis of the contributed property. B. The transfer of appreciated property to a controlled corporation is merely a change in the legal form of ownership of the taxpayer's investment. C. The tax law does not want to punish or discourage entrepreneurs from choosing to do business in the corporate form to avoid unlimited legal liability for business debts. D. Only B & C are correct statements of policy for IRC 351. E. All of the above statements are correct statements of the tax policy rationale for IRC 351.