Lupe and Rodrigo, Father and Son, Each Own 50% of the Stock

Lupe and Rodrigo, father and son, each own 50% of the stock outstanding of Heron Corporation (E & P of $400,000) . During the current year, Heron redeems all of Lupe's shares for $250,000. The transaction cannot qualify as a complete termination redemption if:

A) Three years after the redemption, Lupe receives shares of stock in Heron as a gift from Rodrigo.
B) Lupe received a $250,000 note receivable from Heron in the stock redemption.
C) Lupe loaned Heron Corporation $50,000 two years following the redemption.
D) Rodrigo continued to serve on Heron Corporation's board of directors for five years following the redemption.
E) More than one of the above is correct.