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.

Input: Consider Input: 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

Output: 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


Input: Consider Input: that in December 1995, his wage was $8.67 per hour. Lewis stated that a Caucasian employee, who misrepresented his knowledge of desktop publishing, was hired at a rate of $9.00 per hour in his department. This employee ultimately was “[p]ushed out the door.” Supp.App. at 354. Lewis also stated that another Caucasian employee received a pay increase from $7.50 to $8.25 per hour after he went from part-time to full-time status, and that a third Caucasian employee told him that he received a raise after his father called the store manager. The District Court held that Lewis failed to establish a prima facie case of discrimination because he had not shown that the employees he identified were similarly situated to him. See Watson v. Eastman Kodak Co., 235 F.3d 851, 857-58 (3d Cir.2000) (<HOLDING>). Finally, on his wrongful termination claim, 
 Holding statements: (A) holding that caucasian employees who engaged in the same act as the plaintiff but it did not result in injury to others were not similarly situated (B) holding that a plaintiff who did not show that he was paid at a lower rate than similarly situated employees could not survive summary judgment (C) holding that plaintiff was not similarly situated to another employee who also engaged in protected activity for purposes of plaintiffs retaliation claim (D) holding that employees of differing seniority levels were not similarly situated (E) holding that employee who violated a different policy of the store than plaintiff was not similarly situated

Output: holding that caucasian employees who engaged in the same act as the plaintiff but it did not result in injury to others were not similarly situated


Input: Consider Input: over everything contained anywhere in it.” Leach, 296 Md. at 596, 463 A.2d 872. While executing a valid search warrant, the police found phencyclidine (PCP) in a closed container in a bedroom closet. The Court held that this evidence was insufficient to support the defendant’s conviction, because “fe]ven though [the defendant] had ready access to the apartment, it cannot be reasonably inferred that he exercised restraining or directing influence over PCP in a closed container on the bedroom dresser or over paraphernalia in the bedroom closet.” Id. (emphasis added) Taylor also discussed several decisions of this Court, but in none of these were the illegal substances out in the open or in the plain view of the accused. See, e.g., Tucker v. State, 19 Md.App. 39, 45, 308 A.2d 696 (1973) (<HOLDING>); Barksdale v. State, 15 Md.App. 469, 475, 291 
 Holding statements: (A) holding that a visitor to a hotel room for purposes of distributing drugs failed to establish a reasonable expectation of privacy in the room (B) holding evidence insufficient to establish defendant had physical or constructive possession of heroin when no drugs were found on his person and the only drugs discovered on the premises which he shared with the codefendant were secreted out of plain view (C) holding that the defendants allegations that his codefendant admitted that the defendant had no role in the robbery and that the codefendant had not testified on the defendants behalf because he had been coerced by the state were sufficient to state a prima facie claim of newly discovered evidence (D) holding evidence insufficient to establish defendant had physical or constructive pos session when the drugs that were discovered in a hotel room that he shared with a codefendant were secreted and out of plain view (E) holding that defendant had reasonable expectation of privacy in a hotel room rented by relatives when he had a key to the room and permission to use the room at will


Output: holding that a visitor to a hotel room for purposes of distributing drugs failed to establish a reasonable expectation of privacy in the room