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.

that a declaration of an' express trust of land must be in writing. S.C.Code Ann. 62-7-101 (1987). However, "sufficient part performance of a parol contract for the conveyance of land will remove the contract from the statute of frauds." Stackhouse, 271 S.C. at 521, 248 S.E.2d at 488. To compel specific performance of an oral agreement where part performance is alleged to remove the contract from the statute of frauds, a court of equity must find: 1) clear evidence of an oral agreement; 2) the agreement had been partially executed; and 3) the party who requested performance had completed or was willing to complete his part of the oral agreement. Gibson v. Hrys tlemeyer cannot establish part performance of the alleged agreement. See Stackhouse, 271 S.C. at 521, 248 S.E.2d at 483 (<HOLDING>). Thus, the circuit court did not err by
Holding statements: (A) holding part performance of an oral agreement necessary to take the oral agreement out of the statute of frauds must be consistent only with the existence of the alleged oral contract (B) holding sufficient part performance of an oral trust agreement is required to remove it from the statute of frauds (C) holding that if part performance is relied upon to remove the oral agreement from the operation of the statute of frauds clear and convincing proof of performance in pursuance of the alleged agreement must be adduced by the party seeking to enforce it (D) holding that the statute of frauds bars a breach of contract claim based on an oral agreement to enter a future employment contract that would need to meet the statute of frauds (E) holding a court must find among other things clear evidence of the existence of an oral agreement for part performance to remove the contract from the statute of frauds
holding part performance of an oral agreement necessary to take the oral agreement out of the statute of frauds must be consistent only with the existence of the alleged oral contract