Which One of the Following Allocations Is Most Likely to Meet

Multiple Choice

Which one of the following allocations is most likely to meet the "substantial" test in the "substantial economic effect" rules? (Assume all the "economic effect" tests are met.)

A) The ROY LLC specially allocates $20,000 of income each year to partner Red with no offsetting loss allocations in other years.
B) The YGB LLC specially allocates $30,000 of ordinary income this year to partner Green with an offsetting allocation of loss in that same amount next year.
C) The BPV LLC specially allocates $10,000 of capital gains to Violet and $10,000 of interest income to Purple because Purple is in a lower tax bracket.
D) The PIR LLC specially allocates $60,000 of income to Indigo with no offsetting allocations. Indigo has expiring net operating losses.
E) None of the above items will ever meet the "substantial" test.