With no explanation, chose the best option from "A", "B", "C" or "D". may be “used” in violation of § 924(c), not only as instruments of intimidation or enforcement, but also as tender in a barter transaction, in exchange for drugs. In Bailey v. United States, 516 U.S. 137, 143, 116 S.Ct. 501, 133 L.Ed.2d 472 (1995), the Court held that simply possessing a firearm, without active employment, did not constitute “use” under § 924(c). Following Smith and Bailey, courts of appeals had also held that trading drugs for a firearm constituted “use” under § 924(c)(1)(A). See, e.g., United States v. Harris, 39 F.3d 1262, 1269 (4th Cir.1994) (finding defendant “used” a firearm for purposes of § 924(c) where he gave cocaine base to a compatriot in exchange for assistance in obtaining a gun); United States v. Ramirez-Rangel, 103 F.3d 1501, 1506 (9th Cir.1997) (<HOLDING>); United States v. Ulloa, 94 F.3d 949, 955 (5th

A: holding that a defendant possessed a firearm in connection with a crime when the firearm was kept in a car across the street from where the defendant was selling drugs
B: holding that trading drugs for a firearm constituted use under  924c1a
C: holding that trading drugs for a gun violates the in furtherance of prong of  924c
D: holding that to apply the firearm enhancement the firearm need only reflect the context of the defendants possession and the defendants ability to use the firearm to promote the controlled substance offense
B.