With no explanation, chose the best option from "A", "B", "C" or "D". In re Schmaling, 783 F.2d 680, 683 (7th Cir.1986); see also In re Schneider, 864 F.2d 683 (10th Cir.1988); In re Boyett, 250 B.R. 817, 822 (Bankr. S.D.Ga.2000); In re White, No. BRL88-00971C, 1989 WL 146417 (Bankr.N.D.Iowa Oct.27, 1989); In re Kruse, 35 B.R. 958 (Bankr.D.Kan.1983); Conagra, Inc. v. Farmers State Bank, 237 Mich.App. 109, 602 N.W.2d 390 (Mich.App.1999). A Texas bankruptcy case, frequently cited in this connection, explained that, “the disaster payments are merely the substitute proceeds of the crop which logically would have been received had the disaster or low yields not occurred.” In re Nivens, 22 B.R. 287, 291 (Bankr.N.D.Tex.1982). Nivens ’s reasoning was adopted by the Texas Supreme Court in Sweetwater Prod. Credit Ass’n, v. O’Briant, 764 S.W.2d 230 (Tex.1988)(<HOLDING>). The conclusion of these courts that federal

A: holding that the court was not bound by the parties agreement that contracts were unambiguous and holding that contracts were ambiguous
B: holding the real estate sale proceeds
C: holding payment in kind contracts are proceeds
D: holding student loan proceeds did not lose exempt status after excess of proceeds after payment of tuition and fees was deposited in students bank account
C.