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. The four incorrect answers are other holding statements. You should find the correct option. There is a <HOLDING> token in the position of the citing text prompt where the holding statement was extracted.

Ex Input:
Over Plaintiffs’ Refund Claim. The June 4, 2009 Second Amended Complaint also could be construed as alleging a claim for tax refund, because Plaintiffs request the return of taxes that they allegedly paid. Sec. Am. Compl. at 1-2. The court, however, does not have jurisdiction over this claim, because Plaintiffs have failed to pay the taxes owed in full. 26 U.S.C. § 6511(a). Plaintiffs insist that they fully paid the taxes in intiffs’ Takings Claim. Although Plaintiffs also argue the court has jurisdiction “as described in 28 U.S.C. § 1491, for a claim for just compensation for the taking of property [ ] by the government,” as a matter of law, tax collection is not a cognizable taking under the Fifth Amendment. U.S. Shoe Corp. v. United States, 296 F.3d 1378, 1383 (Fed.Cir.2002) (<HOLDING>). As the United States Court of Federal Claims 
 Holding statements: (A) holding unemployment taxes accrued when employees were terminated not when the amount of compensation taxes are determinable (B) holding that taxes are not private property that can be physically taken by the government (C) holding that taxes were a claim against the estate that had to be filed in probate court thus reversing an order requiring heirs to pay taxes on estate property because the district court did not have jurisdiction (D) holding that when federal government acquires property through condemnation it must account for state and local property taxes interest and penalties (E) holding petitioner could not deduct real estate taxes imposed on property he did not own because these taxes were not imposed on him

Ex Output:
(B)


Ex Input:
Court held that a federal court should not enjoin a state criminal prosecution begun prior to the institution of the federal suit except upon a “showing of bad faith, har-rassment, or any other unusual circumstance that would call for equitable relief.” Younger, 401 U.S. at 53-54, 91 S.Ct. at 754-55. In later cases, the Court has held that the Younger doctrine is “fully applicable to noncriminal judicial proceedings when important state interests are involved.” Middlesex County Ethics Comm. v. Garden State Bar Ass’n, 457 U.S. 423, 432, 102 S.Ct. 2515, 2521, 73 L.Ed.2d 116 (1982); see Moore v. Sims, 442 U.S. 415, 423, 99 S his lower court view, at least by negative inference. See Hawaii Housing Authority v. Midkiff 467 U.S. 229, 237-39, 104 S.Ct. 2321, 2327-29, 81 L.Ed.2d 186 (1984) (<HOLDING>). Since the Commonwealth began this eminent 
 Holding statements: (A) holding that because debtor retained control of property a transfer had not yet occurred (B) holding that where the dispositive issue in an administrative proceeding was whether an accident occurred as the plaintiff alleged it did collateral estoppel did not bar litigation of whether the accident was workrelated because that issue had not yet been litigated (C) holding voluntary dismissal permissible because trial court had not yet reached a decision on the merits (D) holding that younger abstention was not appropriate because eminent domain proceeding had not yet begun when plaintiffs began their federal court action (E) holding that debt collector violated fdcpa when it held debtor liable for court costs that had not yet been awarded

Ex Output:
(D)


Ex Input:
The order was entitled "Amended” because a previous order granting summary judgment omitted dismissal of the counterclaim. These dismissals are not at issue on appeal. 3 . In the motions for summary judgment, appellees did not specifically address Methodist’s request for declaratory judgment. However, Methodist requested merely a declaratory judgment "that the ... claims fertile pre-existing injuries of [Riegert and Fulton-Perez] are entirely Zurich’s responsibility.” Thus, this relief depended on Methodist’s prevailing on its other theories. Further, on appeal, Methodist does not contend the trial court granted more relief than requested in the motions for summary judgment. See Beathard Joint Venture v. W. Houston Airport Corp., 72 S.W.3d 426, 436 (Tex.App.-Texarkana 2002, no pet.) (<HOLDING>). Thus, we will review summary judgment on the 
 Holding statements: (A) holding that where an appellant fails to raise arguments regarding an issue on appeal that issue is deemed abandoned (B) holding that a defendant who fails to raise a specific issue as the basis for suppression in a motion to suppress to the district court has waived the right to raise that issue on appeal (C) holding that evidence filed less than 21 days before original summaryjudgment hearing was timely even though trial court never granted leave to file late evidence because the summaryjudgment hearing was reset to a date more than 21 days after the evidence was filed (D) holding that a party must obtain a distinct ruling on an issue in order to raise it on appeal (E) recognizing appellant must raise issue on appeal that more relief than requested in motion was improperly granted in summaryjudgment order

Ex Output:

(E)