Read the following excerpt from a US court opinion:
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transfers by assignment made to May after the Amendment, including the assignment of income to Berghini Consulting, were ignored by the Bankruptcy Court. A reading of the Bankruptcy Court’s final judgment indicates that the United States’ allegation is well founded; the Bankruptcy Court did focus solely on the transfers made pursuant to the Amendment. This was error. The transfers by assignment were made at a time when the debtor knew about his federal tax liability and these transfers by assignment could have been made in an attempt to evade payment of taxes. After these transfers were made, Sternberg’s assets were beyond the reach of the IRS. All of Sternberg’s asset transfers should have been considered for section 523(a)(1)(C) purposes. See In re Zuhone, 88 F.3d 469 (7th Cir.1996); In re Wright, 191 B.R. 291
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What is the most suitable continuation to the opinion? Your options are:
A. holding the rule against taxpayer standing applies both to federal taxpayers and state taxpayers challenging state tax or spending decisions simply by virtue of their status as state taxpayers
B. holding that intentional reduction of taxpayers salary to avoid garnishment is indicative of intent to evade or defeat tax
C. holding that garnishment of wages is a deprivation
D. holding that garnishment is a distinct civil action
E. holding that a garnishment proceeding is an action against the consumer
Reply with [A, B, C, D, E] only.