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]: were convicted of conspiring to use, carry, or possess a firearm in furtherance of, inter alia, a conspiracy to violate the Neutrality Act and a conspiracy to provide services to the Taliban. 18 U.S.C. §§ 924(c),(o); J.A. 3223. Both Count Five and Count Eleven, in other words, ■ expressly allow one conspiracy to serve as the predicate for another conspiracy. Nothing about this statutory framework is unconstitutional, improper, or even unusual. Courts have recognized that one conspiracy can serve as the predicate for another conspiracy when the “[overarching] conspiracy and the predicate conspiracy are distinct offenses with entirely different objectives.” United States v. Pungitore, 910 F.2d 1084, 1135 (3rd Cir.1990); see also United States v. Ruggiero, 726 F.2d 913, 918 (2nd Cir.1984) (<HOLDING>); United States v. Brooklier, 685 F.2d 1208, 
 Holding statements: (A) holding that two conspiracies existed where the members of the second conspiracy did not know about the first conspiracy did not benefit from the first conspiracy and were connected with the first conspiracy only through a middleman (B) holding that congress intended to allow multiple punishments for rico conspiracies and conspiracies to commit the underlying predicate offense even though the offenses were the same under the blockburger test (C) holding that conspiracies can serve as predicate acts for a rico conspiracy (D) holding that judge erred in not explaining to jury that it could consider predicate acts listed in relation to substantive rico count when deciding whether defendants had also conspired to violate rico (E) recognizing money laundering as a predicate act under rico
[EX A]: holding that two conspiracies existed where the members of the second conspiracy did not know about the first conspiracy did not benefit from the first conspiracy and were connected with the first conspiracy only through a middleman

[EX Q]: Tax Court under subparagraph (A), until the decision of the Tax Court has become final. Rules similar to the rules of sec. 7485 shall apply with respect to the collection of such assessment. (ii) Authority to enjoin collection actions. — Notwithstanding the provisions of sec. 7421(a), the beginning of such levy or proceeding during the time the prohibition under clause (i) is in force may be enjoined by a proceeding in the proper court, including the Tax Court. The Tax Court shall have no jurisdiction under this subparagraph to enjoin any action or proceeding unless a timely petition has been filed under subparagraph (A) and then only in respect of the amount of the assessment to which the election under subsection (b) or (c) relates. 7 See Trent v. Commissioner, T.C. Memo. 2002-285 (<HOLDING>). 8 Respondent has adopted the following 
 Holding statements: (A) holding that the commissioner was not barred by sec 6330e1b from offsetting the taxpayers overpayments for later years against an earlier tax liability for which the taxpayer had claimed relief under sec 6015 (B) holding that it was not the taxpayers responsibility to pursue the different tax units to which the illegally levied county tax was proportioned as the taxpayer was entitled to recover the full amount of the tax from the county the collecting entity (C) holding that a fpaa is the functional equivalent of a notice of deficiency because it serves to afford affected taxpayers that the commissioner has made a final administrative determination of their liability for particular tax years (D) holding the rule against taxpayer standing applies both to federal taxpayers and state taxpayers challenging state tax or spending decisions simply by virtue of their status as state taxpayers (E) holding this court generally lacks jurisdiction over the sec 6651a2 addition to tax for failure to pay tax
[EX A]: holding that it was not the taxpayers responsibility to pursue the different tax units to which the illegally levied county tax was proportioned as the taxpayer was entitled to recover the full amount of the tax from the county the collecting entity

[EX Q]: actual or constructive knowledge of the deceptive nature of its conduct, and (3) the extent to which the purposes of the limitations period have been satisfied. Santa Maria, 202 F.3d at 1176 (citing Naton v. Bank of Cal., 649 F.2d 691, 696 (9th Cir.1981)). Equitable estoppel, then, may come into play “if the defendant takes active steps to prevent the plaintiff from suing in time” — a situation that the Seventh Circuit terms “fraudulent concealment.” Id. at 1176-77 (citing Cada v. Baxter Healthcare Corp., 920 F.2d 446, 450-51 (7th Cir.1990)). “Fraudulent concealment necessarily requires active conduct by a defendant, above and beyond the wrongdoing upon which the plaintiffs claim is filed, to prevent the plaintiff from suing in time.” Id at 1177; accord Boyd, 752 F.2d at 414 (<HOLDING>). B. Johnson’s Failure to Seek Counseling 
 Holding statements: (A) holding an evidentiary hearing on the applicability of equitable estoppel (B) recognizing difference between tolling and equitable estoppel (C) holding that estoppel was a question of fact (D) recognizing cause of action for equitable estoppel under erisa (E) holding that equitable estoppel did not apply because boyd was not affirmatively misled by a postal service official
[EX A]:
holding an evidentiary hearing on the applicability of equitable estoppel