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.

[EX Q]: that post-1978 refinancing of a debt did not constitute a novation, thus debtor could not avoid liens on equipment it owned prior to the 1978 enactment of the Bankruptcy Code where no new money was advanced, no additional security was encumbered, and varying the term of years and interest rates was done to benefit the debtor); In re Hemingson, 84 B.R. 604 (Bankr.D.Minn.1988) (<HOLDING>); Geist v. Converse County Bank (In re Geist),
Holding statements: (A) holding that in georgia pursuant to 9107 of the ucc refinancing of a promissory note transforms the obligation thereby destroying purchase money nature of the security interest therefore the creditor lost its purchase money security interest pmsi in a television set when the loans were consolidated and lien was avoidable id 89 br 264 18 bcd 58 (B) holding that there was no presumption of a gift where the wifes money was used to make the purchase but title was placed in the name of the husband and finding the facts sufficient to establish a purchase money resulting trust in favor of the wife (C) holding that under minnesota law refinancing and consolidation of purchase money loans did not destroy their purchase money character for bankruptcy lien avoidance purposes (D) holding that a purchase money security in jewelry was not lost when the perfected purchase money security interest was consolidated with a subsequent retail installment contract (E) holding section 501 applies to both purchase money and refinancing mortgages
[EX A]: holding that in georgia pursuant to 9107 of the ucc refinancing of a promissory note transforms the obligation thereby destroying purchase money nature of the security interest therefore the creditor lost its purchase money security interest pmsi in a television set when the loans were consolidated and lien was avoidable id 89 br 264 18 bcd 58

[EX Q]: clause could be vitiated based on evidence of fraud "relating to the merger clause or fraud that invalidates the entire contract including the merger clause." 228 Mich.App. 486, 498, 579 N.W.2d 411, 417 (1998). The plaintiffs have not alleged fraud in the merger clause itself. Instead, the plaintiffs allege that the defendants fraudulently induced them to buy investment properties in Detroit. The plaintiffs' allegations of fraud in the inducement do not save their breach of contract claim because the remedy for fraud in the inducement is to void the contract, not reform it. See UAW-GM, 228 Mich.App. at 508, 579 N.W.2d at 418 ("Fraud ... makes a contract voidable at the instance of the innocent party.") (quoting 3 Corbin, Contracts, 580, p. 431); Star Ins. Co., 392 F.Supp.2d at 929 (<HOLDING>). The plaintiffs' argument conflates their tort
Holding statements: (A) holding that a contract made in violation of section 432070 is void rather than voidable (B) holding that irss failure to comply with seizure and sale provisions of section 6335 renders tax sales voidable at taxpayers option rather than void as matter of law (C) holding that the filed rate doctrine precludes insureds fraudulent inducement claim (D) holding that making of agreement to arbitrate was not called into question by general allegation that entire contract was void because of fraudulent inducement (E) holding that fraudulent inducement renders a contract void or voidable
[EX A]: holding that a contract made in violation of section 432070 is void rather than voidable

[EX Q]: Executone Info. Sys., Inc. v. Davis, 26 F.3d 1314, 1320 (5th Cir.1994))). 17 . See Executone, 26 F.3d at 1320 ("We must sustain an arbitration award even if we disagree with the arbitrator's interpretation of the underlying contract as long as the arbitrator's decision 'draws its essence' from the contract." (internal quotation marks and citation omitted)). 18 . See also Parsons & Whittemore, 744 F.2d at 1483-84 (recounting that the arbitration panel awarded postjudgment interest at state statutory rate). 19 . We construe the parties' intentions "generously" to determine whether they agreed to arbitrate a particular issue. See Mitsubishi Motors Corp. v. Soler Chrysler-Plymouth, Inc., 473 U.S. 614, 626, 105 S.Ct. 3346, 87 L.Ed.2d 444 (1985). 20 . Cf. Newmont, 615 F.3d at 1272, 1276 (<HOLDING>). 21 . Riebesell, 586 F.3d at 794;
Holding statements: (A) holding that court should consider issues relating to making and performance of agreement to arbitrate (B) holding that because the parties agreed to arbitrate and both placed the issue before the arbitrator the issue of consolidation was for the arbitrator (C) holding that because the parties agreed to arbitrate the particular issue any doubt about who should decide the consolidation issue was resolved in favor of the arbitrator (D) holding that companys contention that union repudiated the agreement to arbitrate a particular dispute was a matter for the arbitrator and not the court to decide (E) holding that agreement to arbitrate any dispute arising out of contract authorized arbitrator to decide postjudgment interest issues
[EX A]:
holding that court should consider issues relating to making and performance of agreement to arbitrate