TASK DEFINITION: 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.
PROBLEM: the report and recommendation did not notify the parties that they must file timely objections to preserve their right to appellate review. He argues that the firm waiver rule should not be enforced in the absence of such an explicit notification. While we have held that the firm waiver rule is inapplicable when pro se litigants are not given explicit notice of the rule, see id. at 659, we have never extended that practice to counseled cases. We decline to do so today, because we expect counsel to know the rules. See Nasious v. Two Unknown B.I.C.E. Agents, 492 F.3d 1158, 1163 n. 5 (10th Cir.2007) (“[W]e expect counsel to know the pleading rules of the road without being given personal notice of them by the district court.”); United States v. Windrix, 405 F.3d 1146, 1157 (10th Cir.2005) (<HOLDING>). While 28 U.S.C. § 636(b)(1) provides that a 
 Holding statements: (A) holding that district court did not abuse its discretion in striking fact statements that did not comply with the local rules (B) holding that a criminal defendants counsel is charged with knowledge of the local criminal rules in their entirety including those parts of the local civil rules incorporated by reference (C) holding the district court did not abuse its discretion in applying its own local rules even though those rules prevented it from considering some facts improperly alleged by plaintiffs that might have been relevant to the summary judgment motion (D) holding that the federal expert witness compensation rules are in direct conflict with the state rules even when the state rules allow for a greater recovery (E) holding that defendants have a right to counsel in criminal proceedings

SOLUTION: holding that district court did not abuse its discretion in striking fact statements that did not comply with the local rules

PROBLEM: by this Court. The documents presented to the Court are not forms as prescribed by the Secretary of which the Debtors have verified under penalty of perjury. Instead, the Debtors submitted affidavits of Charles D. Tobias and documents entitled “Actual and Constructive Notice of Declaration.” In filing bankruptcy, the Debtors have sought this Court’s protection from creditors, including the Internal Revenue Service. However, the Debtors have continued to ig nore this Court’s orders and the Internal Revenue laws in failing to file tax returns. The Court finds that the Debtors’ disregard of this Court’s orders as well as their duty to file tax returns is evidence that the Debtors lacked good faith in filing this bankruptcy case. Matter of Crayton, 169 B.R. 243, 245 (Bankr.S.D.Ga.1994) (<HOLDING>). Section 1307(c) of Title 11 provides that 
 Holding statements: (A) holding that failure to file correct tax returns constitutes bad faith and makes it difficult for the court to confirm a plan (B) holding that a debtors right to strip off a wholly unsecured lien is conditioned on the debtors obtaining confirmation of and performing under a chapter 13 plan that meets all of the statutory requirements rather than on a debtors discharge (C) holding that order denying confirmation of plan became final when upon being notified that the debtors did not intend to seek confirmation of an alternate plan the court dismissed their case (D) holding that debtors failure to pay postconfirmation taxes pursuant to terms of court order constituted cause for dismissal as a lack of good faith (E) holding on an objection to confirmation of plan that the debtors failure to file tax returns before filing the chapter 13 plan and debtors failure for six months to comply with federal law constituted a lack of good faith sufficient to warrant dismissal of the case

SOLUTION: holding that failure to file correct tax returns constitutes bad faith and makes it difficult for the court to confirm a plan

PROBLEM: to Miranda warnings. Moreover, the government agreed not to submit to the jury any statements that Ahmad Bey made at the interview and Ahmad Bey does not allege that the government broke their agreement. We can quickly dispose of Ahmad Bey’s remaining arguments. She argues that the district court should not have rejected her claim of privilege and allowed the government to call as witnesses the attorneys she hired to file her bankruptcy petitions. But information provided to an attorney in anticipation of a bankruptcy filing is not intended to be held in confidence and therefore is not privileged. United States v. White, 970 F.2d 328, 334 (7th Cir.1992); United States v. White, 950 F.2d 426, 430 (7th Cir.1991); see also United States v. Frederick, 182 F.3d 496, 500 (7th Cir.1999) (<HOLDING>). Ahmad Bey also argues that the government 
 Holding statements: (A) holding defendant liable for intended loss created by filing false tax return for someone else even though intended victim demonstrated to irs that tax return was bogus (B) holding that trial court properly refused to permit disclosure of privileged communications in part because use of the privileged information was not essential to the defense (C) holding that tax returns are privileged under the statutes that prohibited the tax board and employees from disclosing any information and this privilege should not be nullified by allowing third parties to obtain the information by demanding copies of the returns (D) holding that information furnished to preparer of tax return is not privileged (E) holding that intentional failure to file an information return is not a willful filing

SOLUTION:
holding defendant liable for intended loss created by filing false tax return for someone else even though intended victim demonstrated to irs that tax return was bogus