Read the following excerpt from a US court opinion:
```
issues touching upon Plaintiffs’ Count II, which count the Court has yet to rule upon. The Court will not presently rule upon Plaintiffs’ reconsideration request as it respects their Count III given that a future hearing has been scheduled and not yet held regarding the same. However, the Court will now enter its decision regarding Plaintiffs’ Count II. Because the Court’s decision regarding Plaintiffs’ Count III affects the Court’s decision regarding Plaintiffs’ Count II, the Court will first say a few words regarding such Count III. The Court ruled in the I.R.S.’ favor on Count III because the Court determined, in turn, that the I.R.S. is not bound by the terms of the Plan and the Confirmation Order. The Court held that the I.R.S. is not so bound because 23, 127 (Bankr.W.D.Pa.1986) ), as well as the U.S. Supreme Court’s decision
```
What is the most suitable continuation to the opinion? Your options are:
A. holding that the sec does not qualify as a creditor of the estate bound by the confirmed plan pursuant to  1141a and that therefore the sec would thus not be barred from enforcing the securities laws with respect to the violation arising out of the plan notwithstanding its confirmation by court order
B. holding that the power of any administrative agency to reconsider its final decision exists only where the statutory provisions creating the agency indicate a legislative intent to permit the agency to carry into effect such power
C. recognizing such an exception
D. holding that a government agency seeking to enforce a prior order regarding prepetition acts of a debt or is not bound by a confirmed plan a if such agency fails to participate in the confirmation of such plan b if the obligations that such agency seeks to impose upon such debtor do not constitute claims c notwithstanding that such plan purports to treat such debtors obligations to such agency and d since it thus is not a named entity within  1141a
E. holding that a payment is under the plan when the debt is provided for in the plan
Reply with [A, B, C, D, E] only.