Which of the following statements is correct with respect to a partial liquidation?
a. The distribution of proceeds from the sale of excess inventory to shareholders in exchange for part of their stock will not satisfy the not essentially equivalent to a dividend test.
b. The termination of a business test requires that the distributing corporation actively conducted at least three trades or businesses for at least five years.
c. A stock redemption pursuant to a partial liquidation cannot be pro rata with respect to the shareholders.
d. The genuine contraction of a corporate business requirement is an objective test that taxpayers can rely upon with certainty.