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 Q]: in Germantown and Eastern Montgomery County, which the County determined is causing the need to expand the highway system. In Gaithersburg East, the fact that programmed highways are expected to relieve the traffic congestion and there is no need to build unprogrammed highways provides a rational basis to treat the new development in this area differently than the new development in the existing impact districts, where unprogrammed highwa e sub judice is Chapter 808, which gives Montgomery County broad taxing authority, authority that was lacking in those other jurisdictions. See also Home Builders v. Board of Palm Beach County Comm’rs, 446 So.2d 140 (Fla.App. 4th Dist.1983), cert. denied, 451 So.2d 848 (Fla.1984), appeal dismissed, 469 U.S. 976, 105 S.Ct. 376, 83 L.Ed.2d 311 (1984) (<HOLDING>). We likewise hold that the impact tax imposed 
 Holding statements: (A) holding that doctrine does not violate equal protection (B) holding the exclusion did not violate the equal protection clause of the wyoming constitution or the fourteenth amendment to the united states constitution (C) holding that neither the due process clause nor the equal protection clause of the fourteenth amendment require the appointment of counsel on a petition for discretionary review to a state supreme court (D) holding that the impact fee there imposed did not violate the equal protection clause of the fourteenth amendment using the rational basis test we discuss here (E) holding transfer rule did not violate federal equal protection
[EX A]: (D)

[EX Q]: other non-Virginia cases offer a compelling basis for adopting the per se rule Allied has proposed. In National City Bank v. Fleming, 2 Ohio App.3d 50, 440 N.E.2d 590, 599 (1981), for instance, the court said: It has long been the law of equity that a person who confers a benefit either directly or indirectly upon another in the course of performance of a contract with a third person is not entitled to compensation ... merely because of the failure of performance by the third party. However, where it appears from all the facts that the conferral of such benefit was the product of fraud, misrepresentation or bad faith by the party accepting and retaining such benefit, equity will imply an obligation to make payment therefor. See Costanzo v. Stewart, 9 Ariz.App. 430, 453 P.2d 526 (1969) (<HOLDING>), (emphasis added) (some citations omitted). 
 Holding statements: (A) holding that a hospital could not be an erisa beneficiary (B) holding that the thirdparty beneficiary theory did not apply (C) holding that a duty may be owed to a beneficiary of a consensual relationship akin to that of a thirdparty beneficiary of a contract where the professional has actual knowledge that the services being provided are in part for the benefit of such third persons (D) holding that a contract beneficiary may be liable in restitution where the beneficiary by his conduct induces the conferral of the benefit (E) holding change of beneficiary effective where city employee listed a new beneficiary for his group life insurance policy in an employee personal data form next to the words designated beneficiary even though this did not comply with the policy terms
[EX A]: (D)

[EX Q]: justified.” (citing 26 U.S.C. § 7430(c)(4)(B))); see also Schlicher v. Comm’r of Internal Revenue, 73 T.C.M. (CCH) 2501, 2503 (1997) (amendments to I.R.C. Section 7430 shifted the burden to the Government to establish whether its position was substantially justified in proceedings commenced after July 30,1996). I.R.C. Section 7430 does not define “substantially justified,” however, federal appellate courts have interpreted this phrase in considering fee requests under the EAJA. See Sharp v. United States, 20 F.3d 1153, 1154 (Fed.Cir.1994). In the context of an award of attorney fees under the EAJA, the United States Supreme Court has defined “substantially justified” to mean “justified to a degree that could satisfy a reasonable person.” Pierce, 487 U.S. at 565, 108 S.Ct. 2541 (<HOLDING>); see also Huffman v. Commissioner, 978 F.2d 
 Holding statements: (A) holding that the governments position must be justified to a degree that could satisfy a reasonable person and have a reasonable basis in both law and fact citations omitted (B) holding that medical expenses must be proven to be both reasonable and necessary (C) holding that a sale must be both fair and reasonable in price and made in good faith (D) holding that for the administrative position of the government to be substantially justified it must have a reasonable basis both in law and fact (E) holding that congress did not want the substantially justified standard to be read to raise a presumption that the government position was not substantially justified simply because it lost the case citations omitted
[EX A]:
(A)