Read the following excerpt from a US court opinion:
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loss, as required by I.R.C. § 465. Because the Tax Court did not address those arguments, and because we agree that Crispin’s CARDS transaction fails to satisfy the economic substance doctrine, we do not address the Commissioner's other arguments. 16 . The Tax Court noted that the true net cost of the CARDS transaction to Crispin was only $72,926, primarily the structuring fee paid to Chenery and the cost of the Pullman Opinion. The ordinary loss actually reported by Murus, by comparison, was $7,641,706. 17 . With exceptions not relevant in this case, "[t]he basis of property shall be the 7) (same), Gilman v. Comm’r, 933 F.2d 143, 151 (2d Cir.1991) (same), and Massengill v. Comm’r, 876 F.2d 616, 619-20 (8th Cir.1989) (same), with Heasley v. Comm’r, 902 F.2d 380, 383 (5th Cir. 1990) , Gainer v. Comm'r, 893 F.2d 225, 228 (9th
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What is the most suitable continuation to the opinion? Your options are:
A. holding that when the irs totally disallows a deduction the underpayment is not attributable to a valuation overstatement but rather to claiming an improper deduction
B. holding that trial delay for dna testing was attributable to the state but was mere negligence
C. holding that the district court did not abuse its discretion in declining to apply laches where the only prejudice shown by the government was attributable to its own delay rather than to that of the movant
D. holding that valuation should occur on the date of the trial at which property issues are determined
E. holding that dismissal of indictment was abuse of discretion when delay attributable to the government was twelve months
Reply with [A, B, C, D, E] only.