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.

for public use, without just compensation." U.S. Const, amend. V. 16 . Plaintiffs’ April 3, 2009 Complaint alleges that Plaintiffs never received a Notice of Deficiency for any of the tax years at issue. Compl. at 2. Plaintiffs, however, attached a copy of a Notice of Deficiency for 1997 and 1998 in their Petition to the Tax Court challenging the deficiency determinations for these years. Gov't Mot. Ex. C. Further, Plaintiffs did not dispute their receipt of a Notice of Deficiency at the November 15, 2002 CDP hearing. Gov’t Mot. Exs. E, G, H. Section 2514 of Title 28 of the United States Code requires forfeiture of a tax claim when a party attempts to establish its claim through fraud. 28 U.S.C. § 2514; see also Standard Oil v. United States, 98 Ct.Cl. 201, 246, 47 F.Supp. 120 (1942) (<HOLDING>); see also Kamen Soap Products v. United 
 Holding statements: (A) holding that plaintiffs claim for refund of corporate income taxes was forfeited when plaintiff presented forged corporate minutes to the irs with the knowledge they were forged (B) holding that a fraudulent transfer claim against a corporate debtors control person belongs to the corporate debtor not to specific creditors (C) holding that a corporate officer signing a contract in his corporate capacity is generally not liable for damages under the contract (D) holding that the general corporate laws are incorporated into the corporate charter (E) holding that grand jury testimony of officer and inhouse counsel for corporate defendant was properly admitted as admission against the corporate defendant
holding that a fraudulent transfer claim against a corporate debtors control person belongs to the corporate debtor not to specific creditors

was merely acting as Casey’s nominee by allowing him to park 28th Place in her name without relinquishing the benefits of ownership of the property. The district court agreed with the government and allowed forfeiture on this ground. Black’s Law Dictionary defines a “nominee” (in the context of property law) as a “party who holds bare legal title for the benefit of others or who receives and distributes funds for the benefit of others.” Black’s Law Dictionary 1149 (9th ed.2009). Unlike a party with a cognizable property interest, a nominee cannot claim a viable third-party interest sufficient to render a forfeiture invalid. See People v. Chicago Title and Trust Co., 75 Ill.2d 479, 27 Ill.Dec. 476, 389 N.E.2d 540, 544 (1979); United States v. Herrero, 893 F.2d 1512, 1542 (7th Cir.1990) (<HOLDING>), abrogated on other grounds by United States 
 Holding statements: (A) holding lopez was inapplicable to the language prior conviction for a felony drug offense in 21 usc  841b1a because felony drug offense was defined in 21 usc  80244 as an offense that is punishable by imprisonment for more than one year under any law of the united states or of a state (B) recognizing that we held in tilley that the forfeiture of proceeds from illegal drug sales pursuant to 21 usc  881a6 does not constitute punishment (C) holding that drug quantity is an element of an offense under 21 usc  841 (D) holding that scope of property subject to forfeiture is defined by the instrument creating an interest in the property (E) holding that property held by another as nominal owner for benefit of a drug dealer subject to forfeiture under 21 usc  853
holding lopez was inapplicable to the language prior conviction for a felony drug offense in 21 usc  841b1a because felony drug offense was defined in 21 usc  80244 as an offense that is punishable by imprisonment for more than one year under any law of the united states or of a state

644, 646 (Fed.Cir.1994). However, “[mjany, if not most, suits for patent infringement give rise to numerous and complex fact issues, rendering those suits inappropriate for summary disposition.” Union Carbide Corp. v. Am. Can Co., 724 F.2d 1567, 1571 (Fed.Cir.1984). An issue of material fact is genuine “if the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” See Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248, 106 S.Ct. 2505, 91 L.Ed.2d 202 (1986). Where the party opposing summary judgment raises a genuine issue of material fact by proffering expert testimony in conflict with the positions of the moving party, summary judgment is properly denied. See, e.g., Metro. Life Ins. Co. v. Bancorp Serv., L.L.C., 527 F.3d 1330, 1338-39 (Fed.Cir.2008) (<HOLDING>). In determining whether summary judgment is 
 Holding statements: (A) holding that when a plaintiff seeking an injunction raises a genuine issue of fact material to the defendant governments claim regarding its justification for a policy summary judgment is inappropriate (B) holding that the original pto declarations create a genuine issue of material fact (C) holding the conflict in expert declarations created a genuine issue of materi al fact that made summary judgment inappropriate (D) holding that there was a genuine issue of material fact precluding summary judgment (E) holding summary judgment inappropriate to resolve an essentially procedural conflict

holding that when a plaintiff seeking an injunction raises a genuine issue of fact material to the defendant governments claim regarding its justification for a policy summary judgment is inappropriate