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]: Tax Court under subparagraph (A), until the decision of the Tax Court has become final. Rules similar to the rules of sec. 7485 shall apply with respect to the collection of such assessment. (ii) Authority to enjoin collection actions. Notwithstanding the provisions of sec. 7421(a), the beginning of such levy or proceeding during the time the prohibition under clause (i) is in force may be enjoined by a proceeding in the proper court, including the Tax Court. The Tax Court shall have no jurisdiction under this subparagraph to enjoin any action or proceeding unless a timely petition has been filed under subparagraph (A) and then only in respect of the amount of the assessment to which the election under subsection (b) or (c) relates. 7 See Trent v. Commissioner, T.C. Memo. 2002-285 (<HOLDING>). 8 Respondent has adopted the following
Holding statements: (A) holding that the commissioner was not barred by sec 6330e1b from offsetting the taxpayers overpayments for later years against an earlier tax liability for which the taxpayer had claimed relief under sec 6015 (B) holding that it was not the taxpayers responsibility to pursue the different tax units to which the illegally levied county tax was proportioned as the taxpayer was entitled to recover the full amount of the tax from the county the collecting entity (C) holding that a fpaa is the functional equivalent of a notice of deficiency because it serves to afford affected taxpayers that the commissioner has made a final administrative determination of their liability for particular tax years (D) holding the rule against taxpayer standing applies both to federal taxpayers and state taxpayers challenging state tax or spending decisions simply by virtue of their status as state taxpayers (E) holding this court generally lacks jurisdiction over the sec 6651a2 addition to tax for failure to pay tax
[A]: holding that it was not the taxpayers responsibility to pursue the different tax units to which the illegally levied county tax was proportioned as the taxpayer was entitled to recover the full amount of the tax from the county the collecting entity

[Q]: This Court has reviewed these decisions and is in agreement with their reasoning and conclusions that the public policy exception does not give rise to a protected property interest in continued employment in this case. Likewise, the implied covenant is not the source of a protected property interest. The implied covenant of good faith and fair dealing applies to at-will employment and affords an employee the right to be dealt with fairly and in good faith. See Cantwell v. City of Boise, 146 Idaho 127, 191 P.3d 205, 213-14 (2008). Breach of the covenant may give rise to an action for wrongful termination but it does not convert at-will employment to term employment nor form the basis for a protected property interest. See Hollister v. Forsythe, 22 F.3d 950, 952-52 (9th Cir.1994) (<HOLDING>); Willnerd v. Sybase, Inc., No.
Holding statements: (A) recognizing an implied covenant of good faith and fair dealing by all parties in the performance of a contract for the sale of real estate (B) recognizing cause of action for implied covenant of good faith and fair dealing in atwill employment contract (C) holding an implied covenant of good faith and fair dealing was insufficient to create a property interest in continued employment under montanas statutory scheme for at will employment (D) holding that the implied covenant of good faith and fair dealing is limited to performance under a contract (E) recognizing that evidence of breach of implied covenant of good faith and fair dealing may support punitive damages
[A]: recognizing an implied covenant of good faith and fair dealing by all parties in the performance of a contract for the sale of real estate

[Q]: rather than a PTO interference proceeding, we similarly have applied the person of ordinary skill standard in interferences when assessing priority under 120, see Falkner v. Inglis, 448 F.3d 1357, 1365 (Fed.Cir.2006), and see no reason to depart from that standard here. Moreover, 120 requires that the disclosure actually appear within the specification, Lockwood, 107 F.3d at 1571-72 ("It is the disclosures of the applications that count. Entitlement to a filing date does not extend to subject matter which is not disclosed, but would be obvious over what is expressly disclosed. ), and amendments in later applications cannot cure an otherwise defective application in the priority chain, see Encyc. Britannica, Inc. v. Alpine Elecs. of Am., Inc., 609 F.3d 1345, 1351 (Fed.Cir.2010) (<HOLDING>). The incorporation by reference analysis,
Holding statements: (A) holding that dismissal with leave to amend should be granted even if no request to amend was made (B) holding that district court had not abused its discretion in denying plaintiffs motion to amend complaint (C) holding that ijlater applications cannot amend an application and restore its entitlement to priority (D) holding that a court may deny leave to amend when the moving party had the opportunity to amend earlier but waited after judgment to do so (E) holding the district court is not required to grant a plaintiff leave to amend his complaint sua sponte when the plaintiff who is represented by counsel never filed a motion to amend nor requested leave to amend before the district court
[A]:
holding that dismissal with leave to amend should be granted even if no request to amend was made