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:
Salt Lake City Corp. v. Property Tax Div. of Utah State Tax Comm’n, 979 P.2d 346, 351 (Utah 1999) (ruling that continuing denial of a benefit to which a party is entitled provides a basis for standing to obtain judicial review of an administrative rule). The plaintiffs claim that he would be “directly and immediately better off — in the emphatically concrete sense that ... he would have more money in his pocket sooner — if he could obtain relief through the Notice procedure ... without sacrificing a major portion of his claim,” Pl.’s Opp’n at 5, is “[n]o reasonable mind could doubt ... a judicially cognizable injury sufficient to satisfy the injury in fact test for Article III standing,” see Ontario Forest Industries Assoc. v. United States, 444 F.Supp.2d 1309, 1323-24 (CIT 2006) (<HOLDING>) (citing Gen. Motors Corp. v. Tracy, 519 U.S. 
 Holding statements: (A) holding that declaratory judgment requiring party to pay a specific sum of money is properly characterized as a money judgment (B) holding that taking money from a victim offering the money out of fear of violence can be larceny from the person because there is no consent and the money was removed from the actual possession or custody of the person or his immediate pres ence viz the area within his control (C) recognizing that delay of refund deprives plaintiffs of the timevalue of money  and may  deprive plaintiffs of money (D) holding that exhaustion is required under the plra even if the plaintiff seeks only money damages and money damages are not available as relief (E) recognizing that an action will lie for conversion of money when its identification is possible and there is an obligation to deliver the specific money in question or otherwise particularly treat the specific money

Ex Output:
(C)


Ex Input:
Singleton v. Wulff, 428 U.S. 106, 120, 96 S.Ct. 2868, 49 L.Ed.2d 826 (1976). In her reply brief, Ms. Chediek attempts to defend her right to testify concerning her attorneys’ fees and emotional distress by pointing out that these issues were noted in the magistrate judge’s pretrial order. See United States v. Hougham, 364 U.S. 310, 315, 81 S.Ct. 13, 5 L.Ed.2d 8 (1960) (“That pretrial order, as authorized by Rule 16, conclusively established the issues of fact and law in the case....”); Smith v. Washington Sheraton Corp., 135 F.3d 779, 784 (D.C.Cir.1998); Johnson v. Geffen, 294 F.2d 197, 199-200 (D.C.Cir.1960). Because she made this argument for the first time in her reply brief, it is forfeited. See McBride v. Merrell Dow & Pharmaceuticals, Inc., 800 F.2d 1208, 1211 (D.C.Cir.1986) (<HOLDING>). Under the circumstances, the district court’s 
 Holding statements: (A) holding that issues raised for the first time in a reply brief are not reviewable (B) holding arguments first raised in reply brief are forfeited (C) holding that issue raised for the first time in reply brief was waived (D) holding that arguments first raised in appellants reply brief were in answer to those raised in appellees brief and therefore refusing to strike those arguments (E) holding that we do not consider arguments raised for the first time in a reply brief

Ex Output:

(B)