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 Input:
venture” (FAC ¶ 39) are similarly insufficient. See Cannon v. Douglas Elliman, L.L.C., No. 06-CV-7092, 2007 WL 4358456, at *4 n. 3 (S.D.N.Y. Dec. 10, 2007) (“[Pjleading a joint venture does not trigger joint employer status because it is possible for joint ventures to separately employ different people .... ”); Hibbs-Rines v. Seagate Techs., L.L.C., No. 08-CV-5430, 2009 WL 513496, at *5 (N.D.Cal. Mar. 2, 2009) (“Plaintiff joint employer allegations are insufficient because they are legal conclusions, not factual allegations, .... While plaintiff is not required to conclusively establish that defendants were her joint employers at the pleading stage, plaintiff must at least allege some facts in support of this legal conclusion.”) cf. Patel v. Wargo, 803 F.2d 632, 635-36 (11th Cir.1986) (<HOLDING>). Plaintiffs arguments that these Defendants 
 Holding statements: (A) holding under flsa 29 usc  216c (B) holding that the authorization under 29 usc  1132a3 extends to a suit against a nonfiduciary party in interest to a transaction barred by 29 usc  1106a (C) holding under 29 usc  216c (D) holding that the finding that entities constitute a single enterprise under 29 usc  203r is separate and distinct from whether an entity is an employer under 29 usc  203d (E) holding that the defendant is in the best position to prove and should bear the burden of establishing its entitlement to an exemption under 29 usc  1108 from 29 usc  1106b erisas prohibited transactions provision

Ex Output:
holding under flsa 29 usc  216c


Ex Input:
its discretion by modifying the timesharing agreement without evidence that the welfare of the minor child would be promoted by returning him to his former school in Lake County and changing the timesharing arrangement to have the father assume the primary timesharing responsibilities. See § 61.13(3), Fla. Stat. (2014); Holland v. Holland, 140 So.3d 1155 (Fla. 1st DCA 2014); Dobbins v. Dobbins, 584 So.2d 1113, 1116 (Fla. 1st DCA 1991). Accordingly, we reverse and remand for a new hearing. On remand, the court shall take evidence and use the best interests of the child standard to determine if modification is in the child’s best interests in light of the parties’ inability to agree which school the minor child will attend. See, e.g., Watt v. Watt, 966 So.2d 455 (Fla. 4th DCA 2007) (<HOLDING>). Once that determination is made, the trial 
 Holding statements: (A) holding that change of circumstances is not prerequisite to additional   3583e2 modification (B) holding that a hearing is required when a modification of parenting time would change the established custodial environment (C) holding that a showing of a change in circumstances that is or is likely to be beneficial to the child may also warrant a change in custody (D) holding that a custodial parents move to a foreign state without more is not a substantial change of circumstances that would support a modification of custody (E) holding that parties inability to agree on which private high school child would attend constituted substantial change in circumstances warranting modification of parenting plan

Ex Output:
holding that change of circumstances is not prerequisite to additional   3583e2 modification


Ex Input:
been an uncontrolled taxpayer dealing at arm’s length with another uncontrolled taxpayer.” Ruddick Corp. v. United States, 226 Ct.Cl. 426, 643 F.2d 747, 750 (1981) (quoting Treas.Reg. § 1.482-l(c)) (emphasis omitted). Even if plaintiff inadvertently treated its parent in a non-arm’s length manner, section 482 applies. Section 482 in the Internal Revenue Code is the specific provision that may be used to adjust the prices at which goods and services are transferred between entities owned or controlled by the same interests. It is a well-recognized rule of statutory construction that a specific provision controls when the same subject matter is addressed by a more general provision. See Bulova Watch Co. v. United States, 365 U.S. 753, 758, 81 S.Ct. 864, 867-68, 6 L.Ed.2d 72 (1961) (<HOLDING>); Norman J. Singer, Sutherland Statutory 
 Holding statements: (A) holding that in a proceeding to recover taxes from a nonbankrupt taxpayer the taxpayer has the burden of proving that his taxes complied with the internal revenue code (B) holding wills more specific provision prevails over general provision (C) recognizing that the statute of limitations provision of the aedpa is an affirmative defenses rather than jurisdictional (D) holding that interest accruing on an overpayment of taxes attributable to an unused excess profits credit carryback was governed by a specific provision of the internal revenue code rather than by a general provision (E) holding that general obligation to pay money under a disputed provision of the tax code was not a taking

Ex Output:

holding that in a proceeding to recover taxes from a nonbankrupt taxpayer the taxpayer has the burden of proving that his taxes complied with the internal revenue code