Read the following excerpt from a US court opinion:
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to the Guidelines defines sophisticated means as “especially complex or especially intricate offense conduct pertaining to the execution or concealment of an offense.” U.S.S.G. § 2Bl.l(b)(9)(C), n. 8. Here, the record shows that Regensberg conducted a complex and sophisticated scheme, including the creation of fraudulent loan documents, detailed reporting of fake earnings, use of Ponzi scheme payments to lull his investors, and alteration of an account statement to make it appear as if he had not lost his investors’ money. See United States v. Jackson, 346 F.3d 22, 25 (2d Cir.2003) (“[Ejven if each step in the scheme was not elaborate, the total scheme was sophisticated in the way all the steps were linked together....”); United States v. Lewis, 93 F.3d 1075, 1083 (2d Cir.1996) . As in Lewis, Regensberg’s offense conduct,
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What is the most suitable continuation to the opinion? Your options are:
A. holding that the tax was indirect even though the recipient could not shift the tax to others
B. holding that state legislature should determine whether to cure discriminatory tax by enforcing tax as to all or forgiving tax in its entirety
C. holding that state and city tax evasion considered relevant conduct under conviction for federal tax evasion
D. holding that failure to make any tax payment despite having resources sufficient to pay all or a substantial portion of tax liability constitutes evasion
E. holding in tax case that the sophisticated means enhancement applied even when each step in the planned tax evasion was simple because when viewed together the steps comprised a plan more complex than merely filling out a false tax return
Reply with [A, B, C, D, E] only.