In this task, you will be shown a prompt from a judicial decision and multiple holding statements derived from citations following text in a legal decision.  Holdings represent the governing legal rule when the law is applied to a particular set of facts. There are five answer choices for each citing text. The correct answer is the holding statement that corresponds to the citing text. The four incorrect answers are other holding statements. You should find the correct option. There is a <HOLDING> token in the position of the citing text prompt where the holding statement was extracted.

Over Plaintiffs’ Refund Claim. The June 4, 2009 Second Amended Complaint also could be construed as alleging a claim for tax refund, because Plaintiffs request the return of taxes that they allegedly paid. Sec. Am. Compl. at 1-2. The court, however, does not have jurisdiction over this claim, because Plaintiffs have failed to pay the taxes owed in full. 26 U.S.C. § 6511(a). Plaintiffs insist that they fully paid the taxes in intiffs’ Takings Claim. Although Plaintiffs also argue the court has jurisdiction “as described in 28 U.S.C. § 1491, for a claim for just compensation for the taking of property [ ] by the government,” as a matter of law, tax collection is not a cognizable taking under the Fifth Amendment. U.S. Shoe Corp. v. United States, 296 F.3d 1378, 1383 (Fed.Cir.2002) (<HOLDING>). As the United States Court of Federal Claims 
 Holding statements: (A) holding unemployment taxes accrued when employees were terminated not when the amount of compensation taxes are determinable (B) holding that taxes are not private property that can be physically taken by the government (C) holding that taxes were a claim against the estate that had to be filed in probate court thus reversing an order requiring heirs to pay taxes on estate property because the district court did not have jurisdiction (D) holding that when federal government acquires property through condemnation it must account for state and local property taxes interest and penalties (E) holding petitioner could not deduct real estate taxes imposed on property he did not own because these taxes were not imposed on him
(B)

the sufficiency of the evidence,” we “must affirm the verdict ‘if a reasonable trier of fact could conclude from the evidence that the elements of the offense were established beyond a reasonable doubt, viewing the evidence in the light most favorable to the verdict and drawing all reasonable inferences from the evidence to support the verdict.’” Id. (quoting United States v. Myers, 104 F.3d 76, 78 (5th Cir.), cert. denied, 520 U.S. 1218, 117 S.Ct. 1709, 137 L.Ed.2d 834 (1997)). hi. A. The principal issue on appeal is whether the district court erred in admitting the text messages obtained from Govan’s cell phone. First, Govan argues that the district court erred by applying the good-faith exception of United States v. Leon, 468 U.S. 897, 922, 104 S.Ct. 3405, 82 L.Ed.2d 677 (1984) (<HOLDING>). Govan argues that for the good-faith 
 Holding statements: (A) holding that exclusionary rule only requires exclusion of evidence obtained in violation of constitutional rights and that exclusion of evidence obtained in violation of statutory rights is not necessarily required (B) holding that because evidence supporting search warrant was illegally obtained evidence recovered by executing warrant was fruit of the illegal search (C) holding that the fourth amendment exclusionary rule should not bar the use of evidence obtained by police officers acting in good faith and with reasonable reliance on a facially valid search warrant (D) holding that evidence obtained in objectively reasonable reliance on a subsequently invalidated search warrant is not barred by the exclusionary rule (E) holding exclusionary rule inapplicable to evidence obtained by police officers acting in reasonable reliance on search warrant later held invalid
(D)

in'the amendment text. See id. at 421. We specifically addressed use of the term “protect” in the ballot title and summary, and rejected the challenger’s analogy to the use of the term “save” that was rejected in Save Our Everglades, noting that the “use of the term ‘protect’ d[id] not constitute impermissible political rhetoric or the adjudication of a fact.” Workplace Smoking, 814 So.2d at 421. We recognized that we had approved prior ballot titles and summaries containing the term “protect,” and stated that we were “unable to discern the logic as to how the application of essentially the same term” could be acceptable in one case and unacceptable in -another. Id.; see also Advisory Opinion to the Attorney Gen. re Pub. Prot. from Repeated Med. Malpractice, 880 So.2d 667 (Fla.2004) (<HOLDING>). Our analysis in the Workplace Smoking and 
 Holding statements: (A) holding that complaints regarding violation of employer policies unrelated to impermissible discrimination do not fall within the scope of title vii and therefore do not qualify for protection under the statute (B) holding that the use of excessive force does not constitute a prison condition in the ordinary sense of the term (C) holding a 1 signature requirement as within the outer boundaries of support the state may require before affording political parties ballot position (D) holding that the use of the term protection in the ballot title did not constitute impermissible political or emotional rhetoric (E) holding that the erroneous use of the term burglary in the beginning of the written jury instructions was not fundamental because any error was cured by the correct use of the term theft in the latter portion of the written instructions

(D)