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.

[Q]: for public use, without just compensation." U.S. Const, amend. V. 16 . Plaintiffs’ April 3, 2009 Complaint alleges that Plaintiffs never received a Notice of Deficiency for any of the tax years at issue. Compl. at 2. Plaintiffs, however, attached a copy of a Notice of Deficiency for 1997 and 1998 in their Petition to the Tax Court challenging the deficiency determinations for these years. Gov't Mot. Ex. C. Further, Plaintiffs did not dispute their receipt of a Notice of Deficiency at the November 15, 2002 CDP hearing. Gov’t Mot. Exs. E, G, H. Section 2514 of Title 28 of the United States Code requires forfeiture of a tax claim when a party attempts to establish its claim through fraud. 28 U.S.C. § 2514; see also Standard Oil v. United States, 98 Ct.Cl. 201, 246, 47 F.Supp. 120 (1942) (<HOLDING>); see also Kamen Soap Products v. United 
 Holding statements: (A) holding that plaintiffs claim for refund of corporate income taxes was forfeited when plaintiff presented forged corporate minutes to the irs with the knowledge they were forged (B) holding that a fraudulent transfer claim against a corporate debtors control person belongs to the corporate debtor not to specific creditors (C) holding that a corporate officer signing a contract in his corporate capacity is generally not liable for damages under the contract (D) holding that the general corporate laws are incorporated into the corporate charter (E) holding that grand jury testimony of officer and inhouse counsel for corporate defendant was properly admitted as admission against the corporate defendant
[A]: holding that a fraudulent transfer claim against a corporate debtors control person belongs to the corporate debtor not to specific creditors


[Q]: re Haddad), 68 B.R. 944, 948 (Bankr.D.Mass.1987); Williams v. Clark (In re Clark), 91 B.R. 324, 332-34 (Bankr.E.D.Pa.1988). And, although § 105 “does not authorize the bankruptcy courts to create substantive rights that are otherwise unavailable under applicable law,” Pertuso, 233 F.3d at 423, n. 1; “[b]ankruptcy courts ... enjoy inherent power to sanction parties for improper conduct.” Mapother & Mapother v. Cooper (In re Downs), 103 F.3d 472, 477 (6th Cir.1996). This inherent power authorizes federal courts “to protect their proceedings and judgments in the course of discharging their traditional responsibilities.” Degen v. United States, 517 U.S. 820, 823, 116 S.Ct. 1777, 135 L.Ed.2d 102 (1996). See also Chambers v. NASCO, Inc., 501 U.S. 32, 50, 111 S.Ct. 2123, 115 L.Ed.2d 27 (1991)(<HOLDING>); Jones v. Bank of Santa Fe (In re Courtesy 
 Holding statements: (A) recognizing that court has inherent power to control the judicial business before it (B) recognizing inherent power of courts of appeals (C) recognizing district courts inherent authority to dismiss with prejudice for abuse of judicial process (D) recognizing inherent power of federal district court to sanction conduct abusive of judicial process (E) recognizing courts inherent power to impose sanctions including attorneys fees for conduct that abuses the judicial process
[A]: recognizing that court has inherent power to control the judicial business before it


[Q]: (Fed.Cir.1985). “Further, as an additional precaution against denying a party its chance to prove a worthy case, any doubt as to the presence or absence of disputed issues of material fact must be resolved in favor of the presence of disputed issues, or in other words in favor of the party opposing summary judgment.” Lemelson, 760 F.2d at 1261. The onus placed upon a movant for summary judgment on a claim of inequitable conduct is especially heavy, as the claim necessarily involves determinations as to the intent of the party accused of practicing the fraud and the materiality of his alleged misrepresentations or omissions—issues which are typically not appropriate for resolution in a summary fashion. Kangaroos U.S.A., Inc. v. Caldor, Inc., 778 F.2d 1571, 1573-74, 1577 (Fed.Cir.1985) (<HOLDING>). B. Unenforceability Because of Inequitable 
 Holding statements: (A) holding that intent is a separate element and evidence relating to intent is irrelevant to determining whether an object is a criminal instrument (B) holding the connection is an element (C) holding that by including a knowledge element in two sections of a statute the legislature demonstrated that it knew how to express its intent to require a knowledge element rendering the absence of the element in another statute supportive of the inference that the legislature did not intend for there to be a knowledge element (D) holding that specific intent is an element of attempted illegal reentry (E) holding that evaluation of the intent element of inequitable conduct is rarely enabled in summary proceedings
[A]:
holding that intent is a separate element and evidence relating to intent is irrelevant to determining whether an object is a criminal instrument