Read the following excerpt from a US court opinion:
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officer, in violation of 26 [U.S.C. § 7214], for making and signing fraudulent entries, and failing] to perform their duties, making them personally liable for damages.” Id. Any fraud, therefore, “is not one perpetrated by [Plaintiffs], but one by color of law, absent the requirements of law.” Id. at 2-3. In addition, Plaintiffs challenge the Government’s contention that res judicata bars Plaintiffs’ claims, because “[l]ack of jurisdiction either of the person or of the subject matter precludes an administrative determination from being res judicata.” Id. at 3. Since the Notice of Deficiency and certificates of assessment are not valid, “all determination[s] based upon that ignorance is void due to lack of validity.” Id. Finally, Plaintiffs reassert that their Promissory Note (2006) . The United States Court of Federal Claims has
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What is the most suitable continuation to the opinion? Your options are:
A. holding that wages are subject to oregons personal income tax and that a taxpayers argument to the contrary was frivolous
B. holding that this court does not have jurisdiction over tax claims for declaratory or equitable relief
C. holding that the united states court of federal claims does not have jurisdiction to enter declaratory judgment that taxpayers were not liable for any type of federal income tax or to issue injunction permanently removing the tax liens on property and levies on wages
D. holding that interest received by a foreign corporation on a tax refund from the united states was interest on an interestbearing obligation of a resident of the united states within income tax statute
E. holding that taxpayers failure to follow state requirement that he report change in federal income tax did not except state tax liability from discharge
Reply with [A, B, C, D, E] only.