Read the following excerpt from a US court opinion:
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Mr. Robbins asserts that the district court erred in calculating the tax-loss amount attributable to his crimes, a determination which affects his sentence under the advisory Federal Sentencing Guidelines. See U.S.S.G. § 2T1.1. On guideline issues, we review legal questions de novo, factual findings for clear error, and give due deference to the district court’s application of the guidelines to the facts. United States v. Wolfe, 435 F.3d 1289, 1295 (10th Cir.2006). In determining the total tax loss, “all conduct violating the tax laws should be considered as part of the same course of conduct or common scheme or plan unless the evidence demonstrates that the conduct is clearly unrelated.” U.S.S.G. § 2T1.1, cmt. n. 2. See also United States v. Hayes, 322 F.3d 792, 801-02 (4th Cir.2003) . The tax loss proved at trial amounted to
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What is the most suitable continuation to the opinion? Your options are:
A. holding that tax loss may include amounts in returns prepared by the defendant but not included in the indictment
B. holding crimefraud exception applied to testimony of attorney and accountant who prepared his clients tax returns during grand jury investigation for tax evasion
C. holding that tax returns and tax return information cannot regain their confidential status once the returns have become part of the public record by their use in a public trial
D. holding that the lower court erred both in requiring production of copies of the defendants income tax returns and in receiving the returns into evidence over objection
E. holding that tax returns are privileged under the statutes that prohibited the tax board and employees from disclosing any information and this privilege should not be nullified by allowing third parties to obtain the information by demanding copies of the returns
Reply with [A, B, C, D, E] only.