Read the following excerpt from a US court opinion:
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270 A.2d 702 (1970), appeal dismissed, 402 U.S. 902, 91 S.Ct. 1377, 28 L.Ed.2d 643 (1971); Peoples Exp. Co., Inc. v. Director, Div. of Taxation, 10 N.J. Tax 417, 433 (Tax 1989). Such statutory deadlines may not be relaxed. F.M.C. Stores, supra, 100 N.J. at 424-25, 495 A.2d 1313; Black Whale Inc. v. Director, Div. of Taxation, 15 N.J.Tax 338, 347 (Tax 1995). “Statutes of limitation in tax statutes are strictly construed in order to provide finality and predictability of revenue to state and local government.” Bonanno v. Director, Div. Taxation, 12 N.J. Tax 552, 556 (Tax 1992). See also, F.M.C. Stores Co., supra, 100 N.J. at 424-25, 495 A.2d 1313. Cf. Commercial Refrigeration and Fixture Co. v. Director, Div. of Taxation, 184 N.J.Super. 387, 2 N.J. Tax 415, 419, 446 A.2d 210 (Tax 1981) . As explained in Franklin Tp. v. Dep’t of
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What is the most suitable continuation to the opinion? Your options are:
A. holding that after the then twoyear limitation period for the filing of a refund application had passed the state was entitled to assume that its tax revenues need not be refunded under any circumstance
B. holding that a taxpayer only has a refund right after the irs has credited the refund to other underpaid taxes therefore the refund was not part of the bankruptcy estate
C. holding that because the amount of the debtors obligation to the government exceeded the amount of their income tax refund the refund did not become property of the estate and could not be exempted
D. holding that a refund may include additional taxes paid after the filing of a refund claim so long as the total does not exceed the portion of tax paid prior to the administrative claim
E. holding that an erroneous rebate refund revives tax liability because the ultimate source of the irss claim to the amount erroneously refunded is a tax owed
Reply with [A, B, C, D, E] only.