Which of the following is not a required characteristic of a qualifying Section 351 transaction?
a. If more than 20 percent of the stock is transferred for services, property must also be transferred by the service provider.
b. Gain may be recognized if the transferor receives something other than stock.
c. The transferors must control the corporation after the transfer.
d. Control requires only owning 80 percent of the value of the voting stock
e. All are characteristics.