At the Time of His Death, Harvey Was a Shareholder

At the time of his death, Harvey was a shareholder in Grebe Corporation. In valuing the Grebe stock included in Harvey's gross estate, the IRS contends that the corporation possessed considerable goodwill. In disputing this contention, which of the following point(s) is/are relevant?

A) To provide financing, Grebe has been obtaining its working capital from the shareholders at a below market rate of interest.
B) The rate of return used by the IRS for the type of business involved is too high.
C) Average net profit figures do not include large losses from unrelated investments.
D) Harvey was not an employee of Grebe but was merely a passive investor.
E) None of the above.