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. You should write an incorrect option. Even though there exist multiple wrong answers, we only need a single wrong answer. There is a <HOLDING> token in the position of the citing text prompt where the holding statement was extracted.

[EX Q]: Tax Court under subparagraph (A), until the decision of the Tax Court has become final. Rules similar to the rules of sec. 7485 shall apply with respect to the collection of such assessment. (ii) Authority to enjoin collection actions. — Notwithstanding the provisions of sec. 7421(a), the beginning of such levy or proceeding during the time the prohibition under clause (i) is in force may be enjoined by a proceeding in the proper court, including the Tax Court. The Tax Court shall have no jurisdiction under this subparagraph to enjoin any action or proceeding unless a timely petition has been filed under subparagraph (A) and then only in respect of the amount of the assessment to which the election under subsection (b) or (c) relates. 7 See Trent v. Commissioner, T.C. Memo. 2002-285 (<HOLDING>). 8 Respondent has adopted the following 
 Holding statements: (A) holding that the commissioner was not barred by sec 6330e1b from offsetting the taxpayers overpayments for later years against an earlier tax liability for which the taxpayer had claimed relief under sec 6015 (B) holding that it was not the taxpayers responsibility to pursue the different tax units to which the illegally levied county tax was proportioned as the taxpayer was entitled to recover the full amount of the tax from the county the collecting entity (C) holding that a fpaa is the functional equivalent of a notice of deficiency because it serves to afford affected taxpayers that the commissioner has made a final administrative determination of their liability for particular tax years (D) holding the rule against taxpayer standing applies both to federal taxpayers and state taxpayers challenging state tax or spending decisions simply by virtue of their status as state taxpayers (E) holding this court generally lacks jurisdiction over the sec 6651a2 addition to tax for failure to pay tax
[EX A]: holding that it was not the taxpayers responsibility to pursue the different tax units to which the illegally levied county tax was proportioned as the taxpayer was entitled to recover the full amount of the tax from the county the collecting entity

[EX Q]: under Section 15, Article II of the Maryland Constitution. The majority’s greatest foible, however, is in its treatment of the primary issue before this Court, whether the enactment of Senate Bill 1, by which the Legislature removed the PSC Commissioners, constituted an encroachment by the Legislature on the gubernatorial powers enumerated in Sections 1, 9 and 15, Article II of the Maryland Constitution, and a violation of Section 8 of the Declaration of Rights’ separation of powers. Aristotle’s principles, explored by John Locke, and later pragmatically structured by Baron de Montesquieu, are generally credited as the mainstay of the separation of powers doctrine. Edward Rubin, The Myth of Accountability and the Anti-Administrative Impulse, 103 Mich. L.Rev.2073, 2093 n. 59 (2005) (<HOLDING>)-, Jim Rossi, Dual Constitutions and 
 Holding statements: (A) holding that claim premised on the organizing arming and disciplining of members of the national guard involved issue committed expressly to the political branches of government (B) recognizing that the american governments three distinct branches originate from a fusion of concepts found in aristotles the politics john lockes the second treatise of government and montesquieus the spirit of laws (C) recognizing products liability concepts as part of general maritime law (D) recognizing that when other branches of government are remiss in their constitutional duties the judiciary must act (E) recognizing that standing doctrine is fundamentally rooted in respect for the separation of powers of the independent branches of government
[EX A]: holding that claim premised on the organizing arming and disciplining of members of the national guard involved issue committed expressly to the political branches of government

[EX Q]: requirement for personal jurisdiction over nonresidents was satisfied because defendant’s failure to pay child support came within the long-arm statute’s provision providing that a court may exercise limited jurisdiction over an individual when the individual causes "an act to be done, or consequences to occur, in the state resulting in an action for tort.” MCL 600.705(2); MSA 27A.705(2). Plaintiffs position is supported by Black v Rasile, 113 Mich App 601; 318 NW2d 475 (1980), lv den 411 Mich 987 (1981) (a paternity action), which adopted the position of other state courts interpreting the "tortious act” language of their state long-arm statutes. In particular, the Black Court adopted the rationale of an Illinois appeals court, Poindexter v Willis, 87 Ill App 2d 213; 231 NE2d 1 (1967) (<HOLDING>), as well as an Ohio court decision enforcing 
 Holding statements: (A) holding an unborn child is not a child for purposes of criminal prosecution of mistreatment of a child (B) holding that the word tort is not technically construed and hence a fathers breach of the statutory duty to pay child support for his illegitimate child constitutes a tortious act within the meaning of the statute (C) holding that the trial court had erred in imposing an obligation to pay child support when clear and convincing evidence established that the husband was not the father of the child (D) holding that an illegitimate child is guaranteed a right of support from his father (E) holding that an outofwedlock childs pending claim for retroactive child support was nondischargeable in bankruptcy because a debt for child support arises upon the birth of the child and that the fact that no court had yet ordered the debtor to support the child does not take the debt outside the scope of 11 usc  523a5
[EX A]:
holding an unborn child is not a child for purposes of criminal prosecution of mistreatment of a child