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.

of the Islamic Republic of Iran v. Elahi appears to indicate that the assets must be blocked at the time judgment against the asset is finalized. See 556 U.S. 366, 369, 377-79, 129 S.Ct. 1732, 1735, 1739-40, 173 L.Ed.2d 511 (2009) ("We ultimately hold that the Cubic Judgment was not a 'blocked asset' at the time the Court of Appeals handed down its decision.... "). The controlling determination in that case, though, was that the asset in question was never blocked because Iran's interest in it arose after the Treasury Department unblocked all Iranian assets. Id. at 376, 129 S.Ct. at 1739. In Holy Land Foundation, the assets were unreachable because they were unblocked during the pendency of the original civil suit, prior to the commencement of any execution proceeding. 722 F.3d at 687 (<HOLDING>). This rule is not just prescribed by law; it
Holding statements: (A) holding recoupment statute unconstitutional because it did not provide for a hearing prior to entry of judgment (B) holding that because the order lacked an independent basis it was an abuse of discretion to issue the mutual restraining order (C) holding that the governments restraining order against a blocked asset obtained prior to the entry of a civil judgment unblocked it for tria purposes (D) recognizing that a stay contained in anex parte order did not serve to suspend the effectiveness of the restraining notice otherwise any judgment debtor could obtain such an order without notice to the court that a restraining notice had been served or to the judgment creditor and recover his property theretofore properly made the subject of the restraining notice (E) holding that the cubic judgment was not blocked
holding recoupment statute unconstitutional because it did not provide for a hearing prior to entry of judgment

as independent entities that solicited and accepted customer orders but used the services of FCMs for clearing, record keeping and retaining customer funds. See id. at 41. To guarantee the accountability of introducing brokers, the Commission was authorized to require them to meet "minimum financial requirements." See id. First American Discount Corp. v. CFTC, 222 F.3d 1008, 1012 (D.C.Cir.2000). Thus, the legislative history behind the creation of IBs demonstrates Congressional intent not to render IBs agents of FCMs merely because of their status as IBs. Where, as here, the IB is engaged in non-CEA regulated activity, the court concludes that an IB of an FCM is not rendered an agent of the FCM by its mere IB status. See Cunningham v. Waters Tan & Co., 65 F.3d 1351, 1359 (7th Cir.1995) (<HOLDING>); cf. Tatum v. Legg Mason Wood Walker, Inc., 83
Holding statements: (A) holding that an alien is entitled to the fifth amendment guarantee of due process which is satisfied by a full and fair hearing (B) holding that the sixth amendments guarantee of the assistance of counsel is made obligatory upon the states by the fourteenth amendment (C) recognizing that a broad definition of stolen is consistent with the guidelines purposes and finding that the enhancement was properly applied where a defendant found a gun that was lost or mislaid by its owner who never authorized anyone to take the gun never sold it and never gave it away as a gift (D) holding that an fcm by entering into a guarantee agreement with ib as an individual never agreed to guarantee ibs other venture as a commodity pool operator an activity of which fcm was never made aware (E) holding an attorney does not have a duty to insure or guarantee that the most favorable outcome possible and because no amount of work can guarantee a favorable result attorneys would never know when the work they do is sufficiently more than adequate to be enough to protect not only their clients from error but themselves from liability
holding that an alien is entitled to the fifth amendment guarantee of due process which is satisfied by a full and fair hearing

to file on time was not due to willful neglect. See I.R.C. 6651(a)(1). On the face of the matter, these determinations would seem to apply equally to the remainder of the penalty (which was calculated according to the same statutory algorithm and imposed for precisely the same late filing). The Commissioner has pointed to no basis for treating one portion of this unitary penalty differently from the other, and the record suggests no such distinction. The whole is but the sum of its parts, and logically, the two portions of the late-filing penalty should stand or fall together. There may be special circumstances that would justify splitting the baby, but the Commissioner has the burden of identifying those circumstances. Cf. Estate of Abraham v. Comm'r, 408 F.3d 26, 35 (1st Cir.2005) (<HOLDING>). Absent a plausible explanation, the only
Holding statements: (A) holding that where notice of deficiency fails adequately to describe the basis on which the commissioner relies for his deficiency determination burden shifts to the commissioner to prove the accuracy of the deficiency determination (B) holding that a party is not entitled to pursue a separate action for deficiency judgment where the foreclosure complaint includes a prayer for a deficiency judgment and the foreclosure court reserves jurisdiction to enter a deficiency judgment (C) holding that a second deficiency notice issued for a taxable year was valid where it determined a deficiency in a different type of tax than did the earlier deficiency notice (D) holding no jurisdiction when trial court granted extension because it found deficiency even though it was not same deficiency complained of by appellant in his motion to dismiss (E) holding that former sec 272f does not require that the commissioner wait until the period for filing a petition as to a deficiency notice expires before issuing another deficiency notice as to the same taxable year
holding that a party is not entitled to pursue a separate action for deficiency judgment where the foreclosure complaint includes a prayer for a deficiency judgment and the foreclosure court reserves jurisdiction to enter a deficiency judgment