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]: 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 A]: (B)

[EX Q]: Dubuque’s “irrevocable” decision to relocate was not a vote to categorically refuse Dubuque’s overtures, but a vote to insist on financial disclosure as a prelude to bargaining. The Board’s finding that good-faith bargaining between Dubuque and the UFCW might not have been futile was substantially supported by the record. 3. Retroactivity Finally, Dubuque argues that the Board erred by “retroactively” employing its new test in this case. Again, we disagree. Our formulation of the standard for evaluating challenges to the retroactive application of a ruling from an agency adjudication has varied. Compare Retail, Wholesale & Dep’t Store Union v. NLRB, 466 F.2d 380, 390 (D.C.Cir.1972) (applying a five-factor test) with Consolidated Freightways v. NLRB, 892 F.2d 1052, 1058 (D.C.Cir.1989) (<HOLDING>) (internal quotation marks omitted) with 
 Holding statements: (A) holding no retroactive application (B) recognizing a general principle that retroactive application of rules is permitted absent any manifest injustice (C) holding retroactive application (D) recognizing principle (E) holding that retroactive application of amendments will not result in manifest injustice
[EX A]: (B)

[EX Q]: and his fellow Thunderguards members to leave the hall and provide them with identification, a reasonable person would not have felt free to simply ignore the police presence.”); State’s May 12, 2011 Answering Supplemental Memorandum, at 1 ("Outside [the banquet hall], the encounter became less-than-consensual”). 19 . See Weddington v. State, 545 A.2d 607, 612 (Del.1988). 20 . Scheets, 188 F.3d at 836-37. 21 . Id. 22 .Title 24, chapter 13 does not impose criminal sanctions for the unauthorized delivery of private security services. Rather, the Delaware Board of Examiners of Private Investigators and Private Security Agencies has the power to impose a civil penalty up to $200 per day, for each violation. 24 Del. C. § 1311. See also Rickards v. State, 2011 WL 153643, at *1 (Del.2011) (<HOLDING>). Rickards is arguably distinguishable because 
 Holding statements: (A) holding that a police officer may stop a driver where the officer has a reasonable and articulable suspicion regarding the commission of a civil traffic violation (B) holding that an officer can stop an individual if the officer has reasonable articulable suspicion that criminal activity is underfoot (C) recognizing that police officer may stop a suspect if the officer has a reasonable suspicion supported by articulable facts that criminal activity may be afoot (D) holding that a traffic stop is valid under the fourth amendment if the stop is based on an observed traffic violation or if the police officer has reasonable articulable suspicion that a traffic or equipment violation has occurred or is occurring (E) holding that if an officer possesses an objectively reasonable suspicion that a traffic offense has been committed the officer may request identifying information from the driver
[EX A]:
(A)