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.

Q: Discipl. LEXIS 78, *9 (attorney disbursed all settlement proceeds to client less amount he retained for himself, after having been placed on notice that prior attorney claimed an in terest in any settlement funds in violation of Colo, RPC 1.15(b)). III. ANALYSIS OF SANCTION In both the Dunn and McCarthy matters, Rishel engaged in knowing conversion by obtaining funds from third parties for a stated purpose, failing to utilize the funds for that purpose, retaining the funds for an extended period of time after the third parties had withdrawn authorization, and failing to refund the amounts paid to the third parties despite their demand that he do so. The presumptive sanction for knowing conversion of the property of another is disbarment. People v. Dice, 947 P.2d 339, 340 (Colo.1997)(<HOLDING>); Motsenbocker; 926 P.2d at 577 (attorney 
 Holding statements: (A) holding that a defendant has no constitutional right to challenge the search or seizure of property belonging to a third party even if the search was without probable cause (B) holding that a lawyers knowing misappropriation of funds whether belonging to a client or third party warrants disbarment except in the presence of extraordinary factors of mitigation (C) holding that an attorney should not be disbarred for misappropriation of client funds where there were no aggravating factors the attorneys clients did not suffer actual harm and the attorney established several mitigating factors (D) holding that permanent disbarment was appropriate for failure to remit 2000 in settlement funds to client and failing to answer the charges (E) recognizing that a lawyer hired by a third person to represent a client should exercise judgment on behalf of the client independent from the interests of the third person

A: holding that a defendant has no constitutional right to challenge the search or seizure of property belonging to a third party even if the search was without probable cause
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Q: 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

A: holding that a fraudulent transfer claim against a corporate debtors control person belongs to the corporate debtor not to specific creditors
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Q: incident. The Court of Criminal Appeals, in determining that no substantial right of the Def WL 1870426, at *6 (Tenn.Crim.App. May 3, 2013), perm. app. denied (Tenn. Oct. 16, 2013) (“More[o]ver, any error that may have occurred was cured by the prosecutor’s electing the oral sex in closing argument and the trial court’s recalling the jury and issuing the supplemental instruction.” (emphasis added)); State v. Busby, No. M2004-00925-CCA-R3-CD, 2005 WL 711904, at *6 (Tenn.Crim.App. Mar. 29, 2005), perm. app. denied (Aug. 25, 2008) (concluding that “the prosecutor provided such an effective substitute during his closing argument in this case” (emphasis added)); State v. Dearry, No. 03C01-9612-CC-00462, 1998 WL 47946, at *13 (Tenn. CrimApp. Feb. 6, 1998), perm. app. denied (Jan. 19, 1999) (<HOLDING>). Still other decisions from the Court of 
 Holding statements: (A) holding that the prosecutors closing argument effectively served as an election of the proof upon which the state wished to proceed (B) holding that the defendants objection was untimely when he waited until the end of the prosecutors closing argument to raise it (C) holding that prosecutors allegedly improper closing arguments regarding burden of proof defendants failure to testify and other allegations did not case serious doubt upon the correctness of the jury verdict or the fairness of the trial (D) recognizing that a lawyers comments during closing argument may explain away the alleged prejudicial effect of the opposing parties closing argument comments (E) holding thatany error made by the state in its election of offenses was cured during the prosecutors closing argument emphasis added

A:
holding that the defendants objection was untimely when he waited until the end of the prosecutors closing argument to raise it
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