Which of the following statements is false?

A.It is very difficult, if not impossible, for a real estate sale to qualify under IRC1237 if substantial improvements have been made to the property while the property was held by the seller.

B.If a subdivider sells more than five lots in the first taxable year of the subdivision sales, not all of the gain will be capital gain even if the transaction qualifies under IRC1237.

C.If a subdivider/seller of parcels of real estate does not qualify under IRC1237, all of the subdivided parcels are deemed to beheldprimarily for resale in the ordinary course ofthe taxpayer's business.

D.All of the above statements are true.