Which of the following statements most accura tely describes the gain from the sale of property that is substantially appr eciated at the time of the sale?

A It is never passive activity gross income.

B It is passive activity gross inco me if the property was used in a passive activity for 20 perc ent of the taxpayer's holding period.

C It is passive activity gross inco me if the property was used in a passive activity for the 12 months immediately preceding the date of disposition.

D It is always passive activity gross income.