Which of the following requirements does NOT have to be met for a transaction to be considered a Section 351 transaction? (Several answers possible)

A. The transaction must take place within 12 months of the formation (filing of articles of organization) of the corporation.

B. Each shareholder must receive stock in the amount of at least 80% of the value of the property transferred to the corporation.

C. In the aggregate, the transferors of property to the corporation must collectively control the corporation immediately after the transfers.

D. Only property transferred to a corporation is eligible for deferral.

E. All transfers of property to a corporation must be made "simultaneously" (within 12 months) to qualify for deferral