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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.
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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
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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

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(citations omitted). Kaul believes that because the Court did not include seizing cigarettes fi*om Indians inside a reservation on this list, Stephan lacked jurisdiction to execute the search warrant at Kaul's store. However, we do not read Oklahoma Tax Commission and Colville as necessarily prohibiting state officers from conducting search and seizure operations within a reservation's borders under the authority of a federal grant of criminal jurisdiction to the state. Instead, these opinions merely offer several options that state officials may employ to enforce regulatory cigarette tax statutes. Here, Kaul waived the argument that the Kansas statute was regulatory in nature because she did not raise that issue below. Thus, for purposes of this appea 3, 2061, 109 L.Ed.2d 693 (1990) (<HOLDING>). Furthermore, the Supreme Court has long held
Holding statements: (A) holding that a nonmember who files a civil claim in an indian tribal court consents to tribal jurisdiction (B) recognizing the inherent power of indian tribes to exercise criminal jurisdiction over all indians (C) holding that indian tribes lack tribal jurisdiction over crimes committed by nonmember indians within the tribes reservation (D) holding that indian tribes could only exercise criminal jurisdiction over tribal members and not other indians (E) holding that an indian tribes exercise of criminal jurisdiction over nonindians is inconsistent with the domesticdependent status of the tribes and that tribes may not assume such jurisdiction without congressional authorization
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holding that a nonmember who files a civil claim in an indian tribal court consents to tribal jurisdiction

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proceeding, see DelMonico, 116 So.3d at 1213-14, 1217-20, we decline to reach the qualified immunity issue because it was not raised below. See AGM Invs., LLC, 219 So.3d at 927 n.5. Accordingly, we reverse the trial court's order granting summary judgment on count one and remand for further proceedings. In all other respects, we affirm. AFFIRMED, in part; REVERSED, in part; and REMANDED. ORFINGER and WALLIS, JJ., concur. 1 . See Perl v. Omni Int'l of Miami, Ltd., 439 So.2d 316, 317 (Fla. 3d DCA 1983) (concluding that fraud count in complaint based on earlier unemployment compensation case was barred by litigation privilege (citing Robertson v. Indus. Ins. Co., 75 So.2d 198, 199 (Fla. 1954))). 2 . See LatAm Invs., LLC v. Holland & Knight, LLP, 88 So.3d 240, 242-43 (Fla. 3d DCA 2011) (<HOLDING>). Although count three is actually a claim for
Holding statements: (A) holding that a judgment as to the title in a prior litigation was not subject to collateral attack (B) holding that an escrow agent and title insurer may have voluntarily assumed a duty to advise the buyers on their potential legal liability for subcontractors liens on the property in addition to the defendants ordinary contractual and professional duties as an escrow agent and title insurer (C) holding litigation privilege applied to action for abuse of process citing am natl title escrow of fla v guar title tr co 748 so2d 1054 1055 fla 4th dca 2000 (D) recognizing that most other courts apply title vii principles to title ix cases but refusing to apply title viis knew or should have known standard to a title ix claim (E) holding that void deed is neither title nor color of title
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holding that a judgment as to the title in a prior litigation was not subject to collateral attack