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.

[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
[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


[Q]: 511 U.S. 244, 114 S.Ct. 1483, 128 L.Ed.2d 229 (1994). In Landgraf, the Court noted that a statute only truly operates retroactively if applying it would “impair rights a party possessed when he acted, increase a party’s liability for past conduct, or impose new duties with respect to transactions already completed.” Id. 114 S.Ct. at 1505; see also RTC v. Ford Motor Credit Corp., 30 F.3d 1384, 1387-88 (11th Cir.1994)(analyzing retroactivity of lease repudiation damage limitation provision of FIRREA). Thus, like other courts that have analyzed similar FIRREA provisions, we must address prior banking law to determine whether application of the damage limitation provisions of § 1821(e)(3) would have the retroactive effect defined in Landgraf. See, e.g., Ford Motor Credit, 30 F.3d at 1388 (<HOLDING>). We conclude that, in the Crafts’ case, it 
 Holding statements: (A) holding that the act is not retroactive (B) holding that firreas damage limitations for repudiation of leases worked no substantive change in the law and thus their application was not retroactive (C) holding retroactive application (D) holding no retroactive application (E) recognizing that the application of a retroactive amendment is discretionary
[A]: holding that the act is not retroactive


[Q]: subsequent changes in the zoning laws “prohibiting or limiting [a particular] use, the owner must (1) obtain a permit or occupancy certificate where required by applicable ordinance and (2) must proceed under that permit or certificate to exercise it on the land involved so that the neighborhood may be advised that the land is being devoted to that use”) (quoting Richmond Corp. v. Bd. of County Commr’s, 254 Md. 244, 255-56, 255 A.2d 398, 404 (1969)). Although we have not adopted previously the doctrine of zoning estoppel, the principles of equitable estoppel have been considered and applied by both Maryland appellate courts in claims brought against local governments in land use contexts. See Permanent Fin. Corp. v. Montgomery County, 308 Md. 239, 251-53, 518 A.2d 123, 129-130 (1986) (<HOLDING>); Bd. of County Comm’rs v. East Prince 
 Holding statements: (A) holding that an intervening change in statutory interpretation did not amount to a change in controlling law under the mandate rule where plaintiffs attempted on remand to rely on a different but related statute which could have been but was not previously raised and the interpretation of which had not changed (B) holding that stare decisis required the court to adhere to a prior statutory interpretation despite the agencys subsequent interpretation of the statute contrary to the settled law (C) holding erisa plan interpretation is simply one of contract interpretation (D) holding an administrative interpretation cannot change the meaning of a statute or control the courts interpretation of it (E) holding that where a contractor relied on montgomery countys prior reasonable and debatable interpretation of the statutory phrase nonhabitable structures and constructed its building based on that interpretation and with a valid permit it would be inequitable for the county board of appeals to apply a changed interpretation to require removal of the buildings fourth floor
[A]:
holding that an intervening change in statutory interpretation did not amount to a change in controlling law under the mandate rule where plaintiffs attempted on remand to rely on a different but related statute which could have been but was not previously raised and the interpretation of which had not changed