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.

[EX Q]: will “potentially eliminat[e] a substantial expenditure of time, resources, and money of the parties, their counsel, and the Court that may later be determined to have been unnecessary.” Pis.’ Br. filed Nov. 19, 2007, at 9. Because the opinion and order meets all of the requirements for certification, the court, in its discretion, grants plaintiffs’ motion to certify an interlocutory appeal. Accordingly, IT IS ORDERED, as follows: 1. The paragraph of the ordering language on page 25 in the court’s November 9, 2007 opinion and order is amended, as follows: Defendant’s cross-motion for partial summary judgment is granted, and plaintiffs’ motion for summary judgment is denied. Because controlling questions of law are involved with respect to which there are substantial grounds for di 5) 
 Holding statements: (A) holding that gross income can include interest or dividends accruing to fathers ira (B) holding that an overstatement of basis can constitute an omission from gross income within the meaning of irc  6501e1a (C) holding that trial judge has discretion to not include bonuses as part of gross income if he or she determines that the bonus income is not dependable or would place a hardship on a parent (D) holding gross receipts provision provides exception for trade or business to general meaning of gross income provided in section 61a so reporting of gross proceeds alone from sales of commodities would not prevent application of irc  6501e1a (E) holding gross receipts provision to supply exception to general definition of gross income in case of trade or business and applying irc  6501e1a to omission of income
[EX A]: holding that gross income can include interest or dividends accruing to fathers ira

[EX Q]: before section 362(b)(3) can come into play. An act that both creates and perfects a lien postpetition cannot so qualify. See, e.g., Louisville & Jefferson County Metro. Sewer Dist. v. Excel Eng’g, Inc. (In re Excel Eng’g, Inc.), 224 B.R. 582, 589-90 (Bankr.W.D.Ky.1998) (refusing to recognize validity of postpetition creation and perfection of mechanic’s hen because creditor had no lien at the time debtor filed for bankruptcy); Water-vliet Paper Co. v. City of Watervliet (In re Shoreham Paper Co.), 117 B.R. 274, 281-83 (Bankr.W.D.Mich.1990) (finding postpe-tition creation and perfection of property tax lien barred by automatic stay because no prepetition interest existed); Equitable Life Assur. Soc’y v. Ballentine Bros. (In re Ballentine Bros.), 86 B.R. 198, 201 (Bankr. D.Neb.1988) (<HOLDING>); North Side Lumber Co. v. Indus. Indem. Co. 
 Holding statements: (A) holding that the automatic stay barred a suit for injunctive relief to prevent postpetition antitrust violations (B) holding that the automatic stay would be modified so that a credit union could seek payment of postpetition interest from the codebtor (C) holding judgment in violation of automatic stay void (D) holding that creditors failure to voluntarily turn over property lawfully seized prepetition constituted violation of automatic stay (E) holding that creation of a postpetition tax levy based on a prepetition assessment was barred by the automatic stay
[EX A]: holding that the automatic stay barred a suit for injunctive relief to prevent postpetition antitrust violations

[EX Q]: PA, 265 Fed.Appx. 107, 110 (3d Cir.2008) (same; granting summary judgment to defendants under First Amendment); Harbin-Bey v. Rutter, 420 F.3d 571 (6th Cir.2005) (confiscation of inmate’s Five Percenter-related mail did not violate his constitutional rights); Cartwright v. Meade, 2008 WL 2944668 (W.D.Va. July 31, 2008) (confiscation of Five Percenter materials from inmate's cell did not violate the First Amendment); Johnson v. Stewart, 2008 WL 828086 (W.D.Mich. March 26, 2008) (confiscation of Five Percenter literature did not violate First Amendment); Talbert v. Jabe, 2007 WL 3339314 (W.D.Va. Nov. 8, 2007) (confiscation of Five Percenter mail did not violate First Amendment); Cooper v. Starling, 2003 WL 23350443, at *1 (E.D.N.C. Jan. 8, 2003), aff'd, 71 Fed.Appx. 248 (4th Cir.2003) (<HOLDING>). 10 . See, e.g., Brown, 265 Fed.Appx. at 110 
 Holding statements: (A) holding that statute which prohibited polygamy did not violate first amendment (B) holding that a law did not violate the first amendment because it did not burden the exchange of ideas and noting most laws restricting a states initiative process would not implicate the first amendment (C) holding that confiscation of inmates five percenter religious medallion as contraband did not violate the first amendment (D) holding that imposition of government fees did not violate exempt status of religious organization (E) holding that imposition of social security taxes on persons who object to the receipt or payment of public insurance benefits on religious grounds does not violate the first amendment
[EX A]:
holding that statute which prohibited polygamy did not violate first amendment