Teacher: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.
Teacher: Now, understand the problem? Solve this instance: v. Iowa Dept. of Revenue, 792 N.W.2d 308, 328 (Iowa 2010) (concluding Commerce Clause is not offended based on Iowa income tax on royalties earned by allowing use of intangibles within the State of Iowa); Geoffrey, Inc. v. Comm'r of Revenue, 453 Mass. 17, 899 N.E.2d 87, 92 (2009) (applying substantial nexus test and rejecting Commerce Clause challenge based on income earned through use of intangible property in state); Lanco, Inc. v. Director, Div. of Taxation, 379 N.J.Super. 562, 879 A.2d 1234, 1242 (N.J.Super.Ct.App.Div.2005) (finding physical presence of Delaware holding company was not mandatory to impose income tax associated with licensing fees attributable to intellectual property targeting New Jersey consumers); Geoffrey, Inc. v. South Carolina Tax Comm'n, 437 S.E.2d at 18-19 (<HOLDING>); A & F Trademark, Inc. v. Tolson, 167 N.C.App.
Holding statements: (A) holding that by licensing intangibles for use in south carolina holding company had substantial nexus such that taxing royalties from intellectual property would not violate the dormant commerce clause (B) holding that state restrictions on electronic license plates might constitute an undue burden on interstate commerce so the claim fell within the zone of interests protected by the dormant commerce clause (C) holding that the dormant commerce clause applies to the notforprofit sector of the economy (D) holding that state regulations of intrastate wildlife are within dormant commerce clause (E) holding that dormant commerce clause complaint by instate resident against municipality failed on merits because challenged rule regulated evenhandedly and did not burden interstate commerce
Student:
holding that state restrictions on electronic license plates might constitute an undue burden on interstate commerce so the claim fell within the zone of interests protected by the dormant commerce clause