. Which of the following statements regarding Section 351 is incorrect?

A. If the transfer qualifies under 351, the company can elect to defer realized gains or losses.

B. The rationale of deferring realized gains or losses under 351 is to lower the barrier to form a corporation.

C. A control refers to ownership of 80% or more of the corporations voting stock and 80% or more of the total number of shares of each class of nonvoting stock.

D. A boot received cannot cause realized loss to be recognized.

E. Stock options are not eligible for a qualified transfer.