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]: to overcome this presumption by persuading the finder of fact, by a prepon derance of the evidence, that the income tax assessments are erroneous. See Sullivan v. United States, 618 F.2d 1001, 1008 (3d Cir.1980). Klimek has failed to offer any evidence that the tax assessments are incorrect in the amount the Government claims. He has never challenged in the Tax Court the Notices of Deficiency or the Certificates of Assessments and Payments for tax years 1980 through 1988 and 1990 through 1992. Nor has Klimek ever rebutted or even responded to the Government's requests for admissions regarding tax years 1980 through 1988 and 1990 through 1992, except to return them with the words "Refused for Fraud" scrawled across them. See Lane v. United States, 328 F.2d 602, 603 (5th Cir.1964) (<HOLDING>). Given the fact that Klimek bears the burden
Holding statements: (A) holding that a trial court may enter summary judgment for a nonmoving party under appropriate circumstances (B) holding that a trial court is not required to convert a motion to dismiss to a motion for summary judgment where external evidence is submitted if the external evidence is irrelevant to the issue (C) holding that if no countervailing evidence is introduced the trial court is justified in fact required to enter summary judgment for the government the amount of the taxes proved to be due (D) holding that summary judgment is appropriate when no issue of material fact exists and the court is reviewing administrative record for sufficiency of evidence (E) holding that in ruling on a motion for summary judgment the trial court is limited to the grounds raised in the motion
[EX A]: holding that a trial court may enter summary judgment for a nonmoving party under appropriate circumstances

[EX Q]: money judgment can be satisfied out of any of the defendant's assets." Billman, 915 F.2d at 920 (citing United States v. Ginsburg, 773 F.2d 798, 800-03 (7th Cir.1985)). Consequently, after a conviction on a forfeiture count, the district court may order forfeiture of the defendant's substitute assets. The Billman Court then examined the question of whether substitute assets could be restrained pending trial and ruled in the affirmative. 915 F.2d at 920-21. With an eye to the remedial purposes of the forfeiture statute, the court read the provision allowing for a restraining order in connection with the substitute assets provision as calling for the preservation and restraint of substitute assets pending trial. Id. at 921; see also United States v. Skiles, 715 F.Supp. 1567 (N.D.Ga.1989) (<HOLDING>). The Fourth Circuit in Billman relied on
Holding statements: (A) holding that additional witnesses were not needed to corroborate the defendants drug abuse problems because counsel had already introduced sufficient evidence of drug use (B) holding that prior drug trafficking conviction was admissible to prove intent to distribute (C) holding that a state conviction is a drug trafficking offense because the trafficked drug is listed in a csa schedule (D) holding in the drug trafficking context that the government is allowed to restrain additional assets pretrial to ensure sufficient assets for forfeiture (E) recognizing the connection between guns and drug trafficking
[EX A]: holding that additional witnesses were not needed to corroborate the defendants drug abuse problems because counsel had already introduced sufficient evidence of drug use

[EX Q]: judge is not a final order). Accordingly, whatever might be true in other circumstances as to the appealability upon its entry of an order making a priority determination, the Trust could not have appealed as of right from the August 26, 1999 order until after the entry of the order in Adversary Nos. 99-0231 and 99-0524 concluding the adversary proceedings on January 31, 2000, as the August 26, 1999 order did not conclude Adversary No. 99-0231. See In re Professional Ins. Mgmt., 285 F.3d 268, 281 (3d Cir.2002) ("[A] bankruptcy court order ending a separate adversary proceeding is appealable as a final order even though that order does not conclude the entire bankruptcy case.") (internal quotation marks omitted); In re Durability, Inc., 893 F.2d 264, 266 (10th Cir.1990) (per curiam) (<HOLDING>); In re Compton Corp., 889 F.2d 1104, 1106
Holding statements: (A) holding that an order was interlocutory in nature despite the trial courts certification of the order as a final appealable judgment (B) holding that partial summary judgment is not a final appealable judgment when it did not settle completely any of the matters in controversy or adjudicate completely the rights and liabilities of the parties (C) holding that a bankruptcy courts partial summary judgment order that established the priority of one creditor relative to another but did not completely resolve the particular adversary proceeding was interlocutory in nature and therefore not directly appealable (D) holding an order denying a motion for summary judgment is interlocutory and not appealable (E) holding that a rehearing order is interlocutory and not appealable
[EX A]:
holding that an order was interlocutory in nature despite the trial courts certification of the order as a final appealable judgment