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.

Example Input: 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
Example Output: holding that a trial court may enter summary judgment for a nonmoving party under appropriate circumstances

Example Input: their quest had generally confirmed their suspicion. Thereafter it was incumbent upon them to make a decision as to their course of action with "reasonable dispatch." Occidental Life Ins. Co. of North Carolina v. Pat Ryan & Associates, Inc., supra, 496 F.2d at 1268; Johns Hopkins University v. Hutton, supra, 488 F.2d at 917; Baumel v. Rosen, supra, 412 F.2d at 574. The question, therefore, is whether plaintiffs were guilty of unreasonable delay during the period from May 20, 1969 to August 27, 1969. Considering the number of plaintiffs involved and the time necessary for counsel to research legal authorities and draft and prepare the original complaint, this Court concludes that there was no unreasonable delay. Cf. Johns Hopkins University v. Hutton, 343 F.Supp. 245, 255-56 (D.Md.1972) (<HOLDING>), rev'd, 488 F.2d 912 (4th Cir. 1973) (in jury
Holding statements: (A) holding that because the plaintiff had not perfected service within 120 days of filing the complaint the complaint was subject to mandatory dismissal (B) holding inter alia that 130 days was reasonable period for researching and drafting of complaint (C) holding that 120 days notice was satisfied by 30 days work plus 90 days pay (D) holding that delays of 115 days and 101 days were both substantial (E) holding that a difference between 384 days prepreference average number of days to payment and 547 days preference average number of days to payment did not make the payments out of the ordinary course of business
Example Output: holding that because the plaintiff had not perfected service within 120 days of filing the complaint the complaint was subject to mandatory dismissal

Example Input: is narrowly crafted to get to the heart of the motion for summary judgment without allowing a lot of potentially unnecessary discovery. Montoya has said he did not show Wilks or Armijo his computer screen, or tell them Todd's crimes; if Wilks says othexwise, there will likely be a genuine issue of fact requiring .the Court to deny the motions and allow the parties to proceed to trial. It seems fundamentally unfair to dismiss Todd's case when a deposition of Wilks may make his case. Further, this deposition will not burden any government employees or entities. Accordingly, the Court finds that this limited discovery falls within the exceptions to disallowing discovery once the defense of qualified immunity has been raised. See Garrett v. C.A. Stratmen [Stratman], M.D., 254 F.3d at 953 (<HOLDING>). The Court does not believe this one
Holding statements: (A) holding that as a general rule interlocutory trial court orders rejecting defenses of common law sovereign immunity governmental immunity public official immunity statutory immunity or any other type of immunity are not appealable under the maryland collateral order doctrine (B) holding that where defendant claiming qualified immunity relies on facts that are in dispute qualified immunity cannot be granted (C) recognizing that a discovery order in the context of qualified immunity is not immediately appealable when the defendants immunity claim turns at least partially on a factual question when the district court is unable to rule on the immunity defense without further clarification of the facts and which are narrowly tailored to uncover only those facts needed to rule on the immunity claim are neither avoidable or overly broad (D) holding that qualified immunity is not merely immunity from damages but also immunity from suit (E) holding that defendants are not entitled to qualified immunity
Example Output:
holding that as a general rule interlocutory trial court orders rejecting defenses of common law sovereign immunity governmental immunity public official immunity statutory immunity or any other type of immunity are not appealable under the maryland collateral order doctrine