Read the following excerpt from a US court opinion:
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Therefore, Conway has failed to put forward any evidence that National relied on counsel’s advice so as to have reasonable cause for its failure to pay the pre-petition taxes. Similarly, there is no evidence in the record that National’s failure to pay its post-petition taxes was due to reliance on the advice of counsel. Conway’s reference to a few vague and conclusory statements of reliance in the record falls far short of pointing to specific substantive evidence that would support a conclusion that the taxes were not owed. While there is some evidence that counsel told management what debts to pay, no evidence suggests that counsel advised that preferring other creditors would not subject National’s officers to personal liability for the excise taxes. See Newsome, 431 F.2d at 748 . Nor is there evidence of any specific
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What is the most suitable continuation to the opinion? Your options are:
A. holding that an attorneys advice to execute a chattel mortgage in favor of the taxpayers bank did not provide reasonable cause where the attorney did not advise the taxpayer that he could prefer the bank over the united states without sub jecting himself to section 6672 liability
B. holding a bank officer who informed a third party that it would be safe to extend 8000 credit to bank customer although customer did not have an open account at the bank could be held liable for the material misrepresentation
C. holding the bank liable where the bank had almost complete control over the operation of the company during its last three quarters of operation and where withheld taxes were not paid to the irs on instructions from the bank
D. holding that a bank customer did not have a reasonable expectation of privacy in records maintained by the bank
E. holding that a copy of an agreement executed by an insolvent bank found in the draft documents of the banks attorney did not satisfy section 1823es requirements because it was not an official record of the failed bank
Reply with [A, B, C, D, E] only.