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.

Example Input: to overcome this presumption by persuading the finder of fact, by a prepon derance of the evidence, that the income tax assessments are erroneous. See Sullivan v. United States, 618 F.2d 1001, 1008 (3d Cir.1980). Klimek has failed to offer any evidence that the tax assessments are incorrect in the amount the Government claims. He has never challenged in the Tax Court the Notices of Deficiency or the Certificates of Assessments and Payments for tax years 1980 through 1988 and 1990 through 1992. Nor has Klimek ever rebutted or even responded to the Government’s requests for admissions regarding tax years 1980 through 1988 and 1990 through 1992, except to return them with the words “Refused for Fraud” scrawled across them. See Lane v. United States, 328 F.2d 602, 603 (5th Cir.1964) (<HOLDING>). Given the fact that Klimek bears the burden 
 Holding statements: (A) holding that a trial court may enter summary judgment for a nonmoving party under appropriate circumstances (B) holding that a trial court is not required to convert a motion to dismiss to a motion for summary judgment where external evidence is submitted if the external evidence is irrelevant to the issue (C) holding that if no countervailing evidence is introduced the trial court is  justified in fact required to enter summary judgment for the government the amount of the taxes proved to be due (D) holding that summary judgment is appropriate when no issue of material fact exists and the court is reviewing administrative record for sufficiency of evidence (E) holding that in ruling on a motion for summary judgment the trial court is limited to the grounds raised in the motion
Example Output: holding that a trial court may enter summary judgment for a nonmoving party under appropriate circumstances

Example Input: income. As the majority notes, the Internal Revenue Code is not the standard for determining weekly gross income for child support purposes, see op. at ¶ 13 (quoting Child Supp. G. 3(A), cmt. 2(b) that the weekly gross income figure may not be the same as gross income for tax purposes). It may be unfair to exclude all of the settlement proceeds where they have inured to the family’s benefit in the past but it may also be unfair to include all of the proceeds where Scott has need of them for his own care. Commentary to Guideline 3(A) urges judges to “be innovative in finding ways to include income that would have benefited the family had it remained intact, but be receptive to deviations where reasons justify them.” Child Supp. G. 3(A), cmt. 2(b); see also Harris, 800 N.E.2d at 940-41 (<HOLDING>). [5] Because the trial court’s decision was 
 Holding statements: (A) holding the trial court did not abuse its discretion in including only the net amount of settlement proceeds from a wrongful termination lawsuit because that is the amount that would have ultimately benefited the children if the family had remained intact (B) holding that the trial court did not abuse its discretion by ordering a separate trial for the counterclaims where the convenience of the parties would be served (C) holding that the trial court did not abuse its discretion by refusing to accept the defendants guilty pleas to two counts of the indictment and stating that even if the trial court erred the error had not prejudiced the defendant because he was found guilty by the jury of the charges to which he intended to plead and the evidence of the other crimes would have been admissible in the trial for the first degree murder charge (D) holding that when trial court orders restitution at sentencing pursuant to statute the defendant is entitled to notice of the amount claimed and the opportunity to dispute the amount (E) holding prejudgment interest is to be determined on the entire amount of compensatory damages and then reduced by the amount of interest which would have accrued at present value on the settlement amount determined before trial
Example Output: holding that the trial court did not abuse its discretion by ordering a separate trial for the counterclaims where the convenience of the parties would be served

Example Input: case, the bankruptcy court determined, and the district court agreed, that Hilton was the initial transferee. On appeal, Hilton makes two arguments to the contrary. First, Hilton contends that Arlynn, not Hilton, was the initial transferee because Arlynn controlled Video Depot and directed that the funds be transfe .), 73 B.R. 52, 54 (D.D.C.1987) (concluding that principal of corporation was initial transferee when principal arranged for corporation’s purchase of cashier’s check to satisfy financial obligations independent of corporation); Still v. American Nat’l Bank & Trust Co. (In re Jorges Carpet Mills, Inc.), 50 B.R. 84, 85 (Bankr.E.D.Tenn.1985) (same); see also Robinson v. Home Savings of America (In re Concord Senior Housing Foundation), 94 B.R. 180, 183 (Bankr.C.D.Cal.1988) (<HOLDING>). Hilton urges us to reject the rule set forth 
 Holding statements: (A) holding that because the recipient of funds had a contractual obligation to immediately transfer them he was not an initial transferee under  550 even though the funds were eventually used to purchase stock in his name (B) holding that principal who caused debtor to issue cashiers check to satisfy personal obligation was not initial transferee (C) holding that a trustee may settle with an initial transferee and still pursue recovery against a subsequent transferee but notwithstanding the trustee will still be required to prove that the transfers  were fraudulent and improper in connection with its suit against the subsequent transferee because the trustees settlement with the initial transferee did not involve any determination on the merits as to the initial transfers and in this way the subsequent transferee will be afforded its due process rights to contest the avoidability of these initial transfers (D) holding that agent of corporation who used corporate funds to secure personal loan was initial transferee (E) holding a party to be an initial transferee because she was given legal title to the funds
Example Output:
holding that because the recipient of funds had a contractual obligation to immediately transfer them he was not an initial transferee under  550 even though the funds were eventually used to purchase stock in his name