Gerda contributes $$150,000$ to Silver, Inc., for $75\%$ of the stock. In addition, Gerda loans Silver $$450,000.$ The maturity date on the loan is five years, and the interest rate is $8\%,$ the same as the Federal rate. Which of the following statements is true?

a$.$ If the loan is reclassified as equity under $385,$ Silver qualifies for a deduction of $$450,000$ when the loan is repaid, and Gerda receives dividend income of $$450,000($assuming that Silver's earnings and profits are at least $$450,000).$

b$.$ If the loan is not reclassified as equity under $385,$ Silver cannot deduct interest expense nor can Gerda include the interest income of $$36,000$ in the annual gross income.

c$.$ If the loan is not reclassified as equity under $385,$ Silver can deduct interest expense annually of $$36,000,$ and Gerda includes in gross income annually interest income of $$36,000.$

d$.$ If the loan is reclassified as equity under $385,$ Silver claims no interest deduction, but Silver can deduct any dividend payments.

e$.$ If the loan is not reclassified as equity under $385,$ Gerda must pay $$12,000$ annually $(8\%$ of $$150,000).$