Read the following excerpt from a US court opinion:
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such further sum as shall be sufficient to cover the expenses of the levy) by levy upon all property and rights to property ... belonging to such person or on which there is a lien provided in this chapter for the payment of such tax. 26 U.S.C. § 6331(a); see also id. § 6331(d)(4) (enumerating information that must be included with a notice of levy). Although plaintiff argues that the Notice of Levy was deficient because it “did not have a valid OMB number on the form[,] ... did not have a court stamp or ... complete signature,” Compl. U 1, neither section 6331 nor its implementing regulations require this information, see 26 U.S.C. § 6331; 26 C.F.R. §§ 301.6331-1,-2 (2006). Moreover, courts have rejected such arguments. See, e.g., Tavano v. Comm’r, 986 F.2d 1389, 1389 (11th Cir.1993) . Furthermore, section 6331(a) explicitly
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What is the most suitable continuation to the opinion? Your options are:
A. 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
B. holding that a notice of deficiency was invalid where it was the second notice mailed for that year and the taxpayer timely petitioned the court as to the first notice
C. holding that the statute of limitations began to run when the plaintiff first received notice of an alleged deficiency from the irs not when he received a final determination of tax liability
D. holding that a notice of tax deficiency sent to a taxpayer by the irs need not be signed in order to be valid
E. holding that although irs failed to comply with procedures of section 6335 tax sale was valid due to ratification by taxpayer
Reply with [A, B, C, D, E] only.