Minimal presence of MIME headers in message payload

Per RFC 3080 Section 2.2, MIME headers may be used to describe message
payload content:

,----
| A message is structured according to the rules of MIME.  Accordingly,
| each message may begin with "entity-headers" (c.f., MIME's Section 3
| [1]).  If none, or only some, of the "entity-headers" are present:
`----

In the case where /no/ headers are present, is there just a spare CRLF
pair at the beginning of the payload after the BEEP header? That is,
would the following message be valid?

,----
| MSG 0 1 . 0 5
| 
| xxxEND
`----

Or could one send the same content without the spare CRLF pair?

,----
| MSG 0 1 . 0 3
| xxxEND
`----

With the latter, there would be no way to know where the MIME headers
end (given that they never began), so the former example seems more
likely to be the only valid choice. However, this base case with no
headers is hard to resolve from the MIME ABNF, nor are there any
similar header-less examples shown in RFC 3080 or 3081. Clarification
would be appreciated.

-- 
Steven E. Harris