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]: Chief Judge: The appellant, Craig G. Falk, appeals from a July 8, 1996, Board of Veterans’ Appeals (BVA or Board) decision denying his claim service connection for post-traumatic stress disorder (PTSD). As the appellant has limited his appeal to the denial of that claim, the Court deems the appellant to have abandoned his right to appeal with respect to the denial of entitlement to benefits under 38 U.S.C. § 1151. Bucklinger v. Brown, 5 Vet.App. 435, 436 (1993); see also Carbino v. West, 168 F.3d 32, 34-35 (Fed.Cir.1999) (<HOLDING>). Upon consideration of the pleadings of the 
 Holding statements: (A) holding that an issue not presented to the trial court will not be considered on appeal (B) holding that issues not presented in an appellants initial brief to the court need not be considered under this courts rules (C) holding that claims not raised in an appellants initial brief to our court are waived (D) holding that issues not raised in an appellants initial brief are deemed abandoned (E) holding an appellant may not use the reply brief to argue issues not argued in the initial brief
[A]: holding that an issue not presented to the trial court will not be considered on appeal


[Q]: first time a party must specify the statute authorizing attorney’s fees is in the Rule 54 motion (unless otherwise provided by statute or court order). In Missouri, attorney’s fees are not recoverable from another party, except when a contract or statute allows it. Essex Contracting, Inc. v. Jefferson County, 277 S.W.3d 647, 657 (Mo. banc 2009). The second sentence of the Missouri commissions statute is such an exception to the general Missouri rule. Kraft v. Edwards, 946 S.W.2d 775, 776 (Mo.App.1997). The district judge’s ruling that there was no statutory basis for an award of attorney’s fees is erroneous as a matter of law. On remand, the district court should consider whether to award attorney’s fees. See Chem-Trend, Inc. v. Newport Indus., Inc., 279 F.3d 625, 631 (8th Cir.2002) (<HOLDING>). Because this case as tried addressed only 
 Holding statements: (A) recognizing discretion of district court in determining a fee award (B) holding that the most critical factor in determining the reasonableness of a fee award is the degree of success obtained (C) recognizing district courts discretion to consider pending state charge in determining sentence (D) recognizing court discretion in determining reasonable fee under rule 11 (E) holding that attorneys fee award in a common fund case must be  reasonable under the circumstances
[A]: holding that the most critical factor in determining the reasonableness of a fee award is the degree of success obtained


[Q]: In Donaldson v. United States, the Supreme Court explained that the civil rules apply to an IRS summons proceeding, but they do not apply inflexibly. 400 U.S. 517, 528, 91 S.Ct. 534, 541, 27 L.Ed.2d 580 (1971). Rather, “a district court, by local rule or by order, may limit the application of the rules in a summons proceeding ... so long as the rights of the party summoned are protected and an adversary hearing, if requested, is made available.” Id. at 528-29, 91 S.Ct. at 541. The Court in Donaldson approved limiting the application of Rule 24(a)(2), governing intervention as of right, in a tax summons case. Id. Subsequent cases have approved other limitations of the civil rules in IRS summons-enforcement cases. See, e.g., United States v. McCoy, 954 F.2d 1000, 1003-04 (5th Cir.1992) (<HOLDING>); United States v. Vetco, Inc., 691 F.2d 1281, 
 Holding statements: (A) holding that notice to supervisor is notice to city (B) holding that a defendant is not entitled to relief from default judgment because notice to an attorney of filing of motions and orders is constructive notice to the client even when the client did not have actual notice (C) holding that notice of judgment was insufficient (D) holding district court had discretion to modify the threeday notice requirement for default judgment by giving notice in a show cause order (E) holding that actual notice fulfills a notice requirement that an applicable federal regulation be conspicuously posted because actual notice is the best notice
[A]:
holding that notice to supervisor is notice to city