Pallid Swift, Inc

Pallid Swift, Inc., is an S corporation located in Colorado. In the past year, PallidSwift has become profitable; but due to its rapid growth, Pallid Swift has no excess cash for distributions. Therefore, Pallid Swift decides that it should become a C corporation.

A) This transaction qualifies as a "Type F" reorganization.
B) This transaction qualifies as a "Type E" reorganization.
C) This change has no tax significance for Federal purposes.
D) This change is a taxable event.
E) None of the above.