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.

[Q]: challenge to the amount of refund awarded by DOE to a third-party claimant even though they failed to intervene while DOE was deciding the third-party claimant’s award”). Persistent, the defendant analogizes the instant APA claim with that denied in Brooks v. Snow, 313 F.Supp.2d 654 (S.D.Tex.2004). There, the plaintiffs sought a declaration from the court that Treasury Regulation 26 C.F.R. § 301.722-1 (listing the grounds authorizing the IRS to settle a tax case) was inconsistent with congressional intent, because the regulation omitted delays caused by the IRS in determining tax liability. Id. at 658-59. The court dismissed their complaint, explaining that they had not “allege[d] they ever submitted any offers-in-compromise and, therefore, they have not upp. 239, 255 (Ct.Cl. 1947) (<HOLDING>). Second, and most crucially, this plaintiff 
 Holding statements: (A) holding that a refund may include additional taxes paid after the filing of a refund claim so long as the total does not exceed the portion of tax paid prior to the administrative claim (B) holding under section 7422a that the district court lacked jurisdiction over a taxpayers refund claim because the taxpayer failed to file a refund claim before the statute of limitations had run (C) holding that because the amount of the debtors obligation to the government exceeded the amount of their income tax refund the refund did not become property of the estate and could not be exempted (D) holding that a taxpayer only has a refund right after the irs has credited the refund to other underpaid taxes therefore the refund was not part of the bankruptcy estate (E) holding that a subsequent refund request on reassessed taxes was unnecessary as the government already had notice of the plaintiffs claim
[A]: (E)


[Q]: Raye Ellen Stiles appeals pro se from the district court’s summary judgment in her action alleging, among other claims, housing discrimination. We have jurisdiction under 28 U.S.C. § 1291. We review de novo and may affirm the district court on any ground supported by the record. Crowley v. Nevada, 678 F.3d 730, 733-34 (9th Cir.2012). We affirm. Summary judgment on Stiles’ claims for intentional infliction of emotional distress, aggravation of preexisting conditions, and public humiliation was proper because she already litigated these claims in Arizona state court, and, thus, res judicata precludes her from bringing such claims in federal court. See Sunkist Growers v. Fisher, 104 F.3d 280, 283-84 (9th Cir.1997) (<HOLDING>). Summary judgment on Stiles’ federal claims 
 Holding statements: (A) holding that a person has standing to bring suit under the civil rights act if she or he can show that she or he was punished for trying to vindicate the rights of minorities (B) holding that plaintiff had standing to bring a rico conspiracy claim despite his inability to bring a substantive rico claim (C) holding that while parents may not bring a title ix claim as individuals they may bring such claim on behalf of a deceased child (D) holding that under arizona law a litigant may not bring a claim identical to one she has previously litigated (E) holding that plaintiffs may bring a section 1983 claim for damages to vindicate their rights under idea
[A]: (D)


[Q]: victim’s undisputed injuries, this court held that the statute required proof that the bodily injury was a foreseeable, rather than intentional, result of the rights-viólating conduct. Woodlee, 136 F.3d at 1405. At no point did this court even consider the possibility that the statute might not require proof of foreseeability at all, i.e., that the statute, imposed strict liability .on a defendant for bodily .injury resulting from his conduct. Because there is no logical distinction between the statutory language at issue in Woodlee and the language of § 841(b)(1)(E) that we are now tasked with interpreting, I believe that we are bound by Woodlee to interpret § 841(b)(1)(E) as incorporating a proximate cause requirement. See United States v. Ensminger, 174 F.3d 1143, (10th Cir.1999) (<HOLDING>). To conclude otherwise creates an 
 Holding statements: (A) holding that in the absence of an intervening supreme court decision only the en banc court may overrule a decision by a threejudge panel (B) holding that a panel may not reconsider issues decided earlier in the same case by the en banc court (C) holding that one panel of this court is bound by the precedent of an earlier panel absent en banc reconsideration or a superseding contrary decision of the supreme court (D) holding that only intervening law from the supreme court or this court sitting en banc can overrule a prior panel decision (E) holding that we are bound by prior panel opinions until they are overruled or abrogated by the supreme court or this court sitting en banc
[A]:
(C)