Read the following excerpt from a US court opinion:
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remedies must be exhausted.” Id at 810, 554 P.2d at 1307. This Court, in Carter v. State, Dept, of Health & Welfare, 103 Idaho 701, 652 P.2d 649 (1982), reaffirmed this holding by stating: In V-1 Oil Company v. County of Bannock, we held that the proper method of contesting an agency or judicial decision is by appeal, and that an order or judgment may not later be collaterally attacked by means of a declaratory judgment action. The appellants’ collateral attack upon their orders of commitment by means of a declaratory judgment action is thus clearly impermissible. Id at 702, 652 P.2d at 650 (citation omitted); see also Conley v. Looney, 117 Idaho 627, 630, 790 P.2d 920, 923 (Ct.App.1990) (citing Bills v. State Dept, of Revenue and Taxation, 110 Idaho 113, 714 P.2d 82 (Ct.App. 1986)) . Count I of Ag Air’s amended complaint seeks
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What is the most suitable continuation to the opinion? Your options are:
A. holding that appellant hjaving failed to exercise administrative appeal  cannot now collaterally attack the tax deficiency determination in an independent action
B. holding that a party could not collaterally attack a default judgment obtained against him in a foreclosure action
C. holding that a defendant cannot collaterally attack his sentence under 18 usc  3582c2
D. holding that where notice of deficiency fails adequately to describe the basis on which the commissioner relies for his deficiency determination burden shifts to the commissioner to prove the accuracy of the deficiency determination
E. holding that a second deficiency notice issued for a taxable year was valid where it determined a deficiency in a different type of tax than did the earlier deficiency notice
Reply with [A, B, C, D, E] only.