Besides the Statutory Requirements for Tax-Free Treatment for Corporate Reorganizations

Besides the statutory requirements for tax-free treatment for corporate reorganizations, there are several judicial requirements. Which of the following is not a judicial requirement for corporate reorganizations?

A) The ownership change doctrine should be met.
B) The continuity of business enterprise test must be met.
C) There must be a sound business purpose for the restructuring.
D) The step transaction doctrine should not apply.
E) All of these items are judicial requirements for reorganizations.