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.

Ex Input:
in Germantown and Eastern Montgomery County, which the County determined is causing the need to expand the highway system. In Gaithersburg East, the fact that programmed highways are expected to relieve the traffic congestion and there is no need to build unprogrammed highways provides a rational basis to treat the new development in this area differently than the new development in the existing impact districts, where unprogrammed highwa e sub judice is Chapter 808, which gives Montgomery County broad taxing authority, authority that was lacking in those other jurisdictions. See also Home Builders v. Board of Palm Beach County Comm’rs, 446 So.2d 140 (Fla.App. 4th Dist.1983), cert. denied, 451 So.2d 848 (Fla.1984), appeal dismissed, 469 U.S. 976, 105 S.Ct. 376, 83 L.Ed.2d 311 (1984) (<HOLDING>). We likewise hold that the impact tax imposed 
 Holding statements: (A) holding that doctrine does not violate equal protection (B) holding the exclusion did not violate the equal protection clause of the wyoming constitution or the fourteenth amendment to the united states constitution (C) holding that neither the due process clause nor the equal protection clause of the fourteenth amendment require the appointment of counsel on a petition for discretionary review to a state supreme court (D) holding that the impact fee there imposed did not violate the equal protection clause of the fourteenth amendment using the rational basis test we discuss here (E) holding transfer rule did not violate federal equal protection

Ex Output:
(D)


Ex Input:
failed to complete the assignment and warranty of title to H & L on the same certificate. See Ga. Code Ann. Sec. 40-3-32(a) (Supp. 1988). Winn is still listed on the certificate as the registered owner, and under Georgia law, the certificate is prima facie evidence of the facts appearing on it. Ga. Code Ann. Sec. 40-3-25(c) (1985). Although our reading of the Georgia statutes yields the conclusion that ownership of the Buick did not pass to the dealership or to H & L since the certificate of title was not properly assigned, it appears that Georgia courts interpreting the same statutes would reach a different conclusion. See, e.g., American Mut. Fire Ins. Co. v. Cotton States Mut. Ins. Co., 149 Ga. App. 280, 253 S.E.2d 825 (1979); Mote v. Mote, 134 Ga. App. 668, 215 S.E.2d 487 (1975) (<HOLDING>). Thus, Winn’s evidence regarding the sale of 
 Holding statements: (A) holding that a seller could enforce an arbitration provision against a buyer even though only the buyer had signed the provision (B) holding that ownership of vehicle later involved in accident passed to buyer even though assignment of title not completed (C) holding that in pennsylvania there is a rule that proof of the ownership of a business vehicle involved in an accident raises a presumption that the operation of the automobile was for the owners business purposes (D) holding that a purchaser of a vehicle was a buyer in the ordinary course of business even though the car dealer did not provide the certificate of title at the time of the sale (E) holding that delivery of possession of vehicle without delivery of certificate of title did not transfer ownership even though full payment had been received

Ex Output:
(B)


Ex Input:
instant case, the loss of the administrative file gives rise to the possibility that the penalty assessment in question lacks foundation. As described in Janis and its progeny, however, an assessment is not “naked” simply because the administrative file supporting its entry is lost — what is critical, given the de novo nature of the proceedings before this court, is that admissible evidence exists to support the assessment. See Estate of Magnin v. Commissioner, 184 F.3d 1074, 1081 (9th Cir.1999); Karme v. Commissioner, 673 F.2d 1062, 1065 (9th Cir.1982). If such evidence exists, and is admitted by the court, it is irrelevant whether it is the same evidence that the Service relied upon in originally making its assessment. See Coleman v. United States, 704 F.2d 326, 329 (6th Cir.1983) (<HOLDING>). Indeed, consistent with the “no-look” 
 Holding statements: (A) holding that agency decisions enjoy a presumption of correctness (B) holding evidence insufficient to overcome presumption of correctness (C) holding that because there was no factual dispute between the parties the presumption of correctness is not relevant (D) holding that although the presumption of correctness applies to the ultimate classification decision  the presumption carries no force as to questions of law (E) holding that assessment was naked but noting that secondhand records or any demonstrably reasonable methodology of estimation may be used to establish presumption of correctness

Ex Output:

(E)