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.

of not more than 15 years, and it similarly concluded as follows: If a sentence under this paragraph provides for imprisonment, the sentence shall include a special parole term of not less than three years in addition to such term of imprisonment. 21 U.S.C. § 960(b)(1). The language of §§ 841(b)(1)(A) and 960(b)(1) thus squarely contradicts Walberg’s contention, for each stated that the special parole term shall be a minimum of a certain number of “years in addition to [the] term of imprisonment.” Accord United States v. Mack, 509 F.2d 615, 616 (9th Cir.1974) (per curiam), cert. denied, 421 U.S. 916, 95 S.Ct. 1578, 43 L.Ed.2d 783 (1975); Llerena v. United States, 508 F.2d 78, 82 (5th Cir.1975). Cf. Bifulco v. United States, 447 U.S. 381, 388, 100 S.Ct. 2247, 2252, 65 L.Ed.2d 205 (1980) (<HOLDING>). The legislative history of the Act and the 
 Holding statements: (A) holding conviction for cce murder 21 usc  848e1 is a separate offense from a cce 21 usc  848c (B) holding that no special parole term was authorized for a conviction for conspiracy in violation of 21 usc  846 which mentioned only fine and imprisonment and not special parole and emphazing the in addition to language of 21 usc  841b1b (C) holding that in order for a trial court to determine which of the three graduated penalty subsections of 21 usc  841b applies to defendants convicted of a  846 drug conspiracy the jury must be instructed to determine the threshold quantity of drugs attributable to each conspiracy defendant on trial (D) holding that the elements of a drug conspiracy under 21 usc  846 do include an overt act requirement (E) holding lopez was inapplicable to the language prior conviction for a felony drug offense in 21 usc  841b1a because felony drug offense was defined in 21 usc  80244 as an offense that is punishable by imprisonment for more than one year under any law of the united states or of a state
holding conviction for cce murder 21 usc  848e1 is a separate offense from a cce 21 usc  848c

669 (1971). Although Plaintiff requests resolution of seemingly unsettled State law questions, the issues at bar fall squarely within the Burford parameters: Plaintiff has presented difficult issues of state law, gaming is arguably an area of important state policy in Texas, and the Texas Lottery Commission (TLC) provides the unified State enforcement mechanism for some aspects of gaming law in Texas. Moreover, both the TLC and Office of the Attorney General provide an administrative procedure for organizations and individuals to request advisory opinions regarding the legality of proposed gaming actions. Certification to the Texas Supreme Court to answer the state law question at issue here would be ideal. See Lehman Bros. v. Schein, 416 U.S. 386, 94 S.Ct. 1741, 40 L.Ed.2d 215 (1974)(<HOLDING>). However, under the Texas Constitution, 
 Holding statements: (A) holding that the decision to transfer rests within the sound discretion of the district court (B) holding that certification of a remand order divests federal court jurisdiction (C) holding that the decision to transfer rests within the sound discretion of the court (D) holding that it was proper in determining certification to consider whether certification would foster the settlement of the case with advantage to the parties and with great savings in judicial time and services (E) holding that certification to the state supreme court rests in the sound discretion of the federal court and that certification in the long run saves time energy and resources as well as helps to build a cooperative judicial federalism
holding that the decision to transfer rests within the sound discretion of the district court

2008, as evidenced by Exhibit B to Plaintiffs’ April 3, 2009 Complaint, i.e., a “Certified Promissory Money Note[,]” that states it is a “U.C.C. negotiable instrument redeemable at full face value when presented to [Plaintiffs’ address].” Pl. Ex. B. Plaintiffs later corrected the Promissory Note and proffered it in Plaintiffs’ July 10, 2009 Addendum. Pl. Add. Ex. A. This Promissory Note, however, is not a payment of the taxes due, because it is not a “means of cash or cash equivalents” as required by Section 6311 of the Internal Revenue Code. 26 U.S.C. § 6311; see also 26 C.F.R. § 301.6311-1. Therefore, since Plaintiffs have not paid the taxes at issue, the court does not have jurisdiction over Plaintiffs’ tax refund claim. Shore v. United States, 9 F.3d 1524, 1526 (Fed.Cir.1993) (<HOLDING>). c.The Court Does Not Have Jurisdiction Over 
 Holding statements: (A) holding that in statute authorizing suits against united states limits time period in which such suits may be brought united states retains its sovereign immunity as to any suits brought outside of that time period therefore court does not have subject matter jurisdiction over suit against united states that is barred by statute of limitations (B) holding that a tax refund claim must be dismissed if the principal tax deficiency has not been paid in full (C) holding that the full payment rule is applicable to refund suits in the court of federal claims (D) holding that interest received by a foreign corporation on a tax refund from the united states was interest on an interestbearing obligation of a resident of the united states within income tax statute (E) holding that full payment of the assessment is also required for tax refund suits brought in the united states court of federal claims

holding that in statute authorizing suits against united states limits time period in which such suits may be brought united states retains its sovereign immunity as to any suits brought outside of that time period therefore court does not have subject matter jurisdiction over suit against united states that is barred by statute of limitations