Read the following excerpt from a US court opinion:
```
opinion supplements and amends a letter opinion I issued on June 15, 2007 denying cross-motions for summary judgment because genuine issues of material fact existed, see R. 4:46-2(c), and my bench opinion of September 7, 2007 in which I made certain factual findings but did not decide the merits of these appeals. This opinion is based on the certifications and documents submitted in connection with the summary judgment motions as well as the testimony and documents presented at a plenary hearing on September 7, 2007, and my evaluation of the credibility of the witnesses. 3 Under I.R.C. § 1031(a), the “taxpayer” must effect the exchange, that is, the same taxpayer must be transferor and transferee in the exchange transaction. See Chase v. Commissioner, 92 T.C. 874, 1989 WL 38262 (1989) . 4 Because single member limited liability
```
What is the most suitable continuation to the opinion? Your options are:
A. holding that a transaction did not satisfy the requirements of  1031a when a partnership sold property and individual partners acquired the exchange property
B. holding that tjhere is a strong legal presumption that all property acquired during marriage is community property
C. recognizing that partnership property is a type of ownership
D. holding lease of property was a commercial transaction where the property was for commercial ranching but a residence was maintained on the property
E. holding under oregons larceny statute which is based on new yorks larceny statute that a partner cannot be charged with the theft of partnership property because oregon adheres to the commonlaw rule that partners cannot steal partnership property
Reply with [A, B, C, D, E] only.