Ralph's Business Records Were Lost as a Result of Hurricane

Ralph's business records were lost as a result of Hurricane Katrina. CPA Jane prepares Ralph's return using estimates. What do the Statements on Standards for Tax Services state about the use of estimates?

A) The Statements on Standards for Tax Services do not address the use of estimates.
B) Estimates may not be used.
C) Estimates may be used without disclosing their use to the IRS.
D) Estimates may be used, but Jane should disclose their use to the IRS.