Read the following excerpt from a US court opinion:
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of “relation back” to give the beneficiary of a constructive trust priority over private intervening interests, this would not be determinative as to the IRS. The priority of a federal tax lien against competing claims is governed by federal law. See United States v. Dishman Independent Oil, Inc., 46 F.3d 523, 526 (6th Cir.1995) (“It is undisputed that when a federal lien is involved, the relative priority between competing liens is a question of federal law determined by the principle ‘the first in time is the first in right.’ ”). Federal law, however, makes no provision for the subordination of a tax lien through the use of the “relation back” doctrine. See id. at 527; United States v. Security Trust & Savings Bank of San Diego, 340 U.S. 47, 50, 71 S.Ct. 111, 95 L.Ed. 53 (1950) ; Drye v. United States, 528 U.S. 49, 120 S.Ct.
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What is the most suitable continuation to the opinion? Your options are:
A. holding that a lien holder who is not served and joined as a party to a tax suit cannot have his lien extinguished by the tax sale
B. holding that a state tax lien was not judicial lien arising from judgment such that it could be avoided in bankruptcy by a chapter 13 debtor
C. holding that the lien bond releases the property from the lien but the lien is then secured by the bond
D. holding that a property right that comes into existence by court action such as a judgment lien does not relate back to some earlier date to destroy the priority of a federal tax lien
E. holding that a judgment resolving the question of the priority of the federal tax lien   constitutes a final and appealable order over which we have jurisdiction
Reply with [A, B, C, D, E] only.