Read the following excerpt from a US court opinion:
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CURIAM In this appeal from a decision of the Oregon Tax Court, Gary Allan Clark (taxpayer) challenges both the Tax Court’s conclusion that he is liable for 1996 personal income taxes based on wages that he earned in that tax year and the Tax Court’s assessment of damages against him for pursuing a frivolous appeal. See ORS 305.437 (authorizing sanctions for frivolous or groundless appeals to Tax Court). The Tax Court’s rulings were correct. See Combs v. Dept. of Rev., 331 Or 245, 14 P3d 584 (2000) . Only one of taxpayer’s assertions merits
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What is the most suitable continuation to the opinion? Your options are:
A. holding that the united states court of federal claims does not have jurisdiction to enter declaratory judgment that taxpayers were not liable for any type of federal income tax or to issue injunction permanently removing the tax liens on property and levies on wages
B. holding that taxpayers failure to follow state requirement that he report change in federal income tax did not except state tax liability from discharge
C. holding as frivolous taxpayers argument that he was not subject to the income tax because he is a non resident alien and awarding sanctions of 8000
D. holding that wages are subject to oregons personal income tax and that a taxpayers argument to the contrary was frivolous
E. holding that an appeal by taxpayers in a lawsuit seeking to enjoin the government from collecting income tax deficiencies was mooted because the taxpayers had paid the deficiencies pending the appeal
Reply with [A, B, C, D, E] only.