Which of the following statements is false?

A. If the taxpayer's real estate is classified as an investment, generally the sale of such property will result in capital gain or loss unless IRC1231 applies where any net loss will be ordinary loss.

B. The issue of whether a particular parcel of real estate is dealer property or investment property is a generally a question of fact, and has resulted in much litigation.

C . If the real estate sales were infrequent. were the result of unexpected changes in circumstances, or from unsolicited offers (i.e. no advertising), such sales are more likely to be treated as investment property.

D. When sizable improvements are made to real property to facilitate the sale of lots. the IRS' position is that such real property has become inventory.