With no explanation, chose the best option from "A", "B", "C" or "D". (2003). The Guidelines define sophisticated means as: especially complex or especially intricate offense conduct pertaining to the execution or concealment of an offense. For example, in a telemarketing scheme, locating the main office of the scheme in one jurisdiction but locating soliciting operations in another jurisdiction ordinarily indicates sophisticated means. Conduct such as hiding assets or transactions, or both, through the use of fictitious entities, corporate shells, or offshore financial accounts also ordinarily indicates sophisticated means. Id. cmt. (n.6(B)). While we have not expressly stated what qualifies as sophisticated means, we have held “sophisticated means involves more than minimal planning.” United States v. Humber, 255 F.3d 1308, 1314 (11th Cir.2001) (<HOLDING>). The district court did not clearly err in

A: holding even minimal payment required by the icrp could be beyond the debtors means
B: holding sophisticated means and the now defunct more than minimal planning enhancements could be applied cumulatively
C: holding that to grant a new trial the error must be more than harmless
D: holding that more than notice to a defendant is required
B.