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. The four incorrect answers are other holding statements. You should find the correct option. There is a <HOLDING> token in the position of the citing text prompt where the holding statement was extracted.

[Q]: challenge to the amount of refund awarded by DOE to a third-party claimant even though they failed to intervene while DOE was deciding the third-party claimant's award"). Persistent, the defendant analogizes the instant APA claim with that denied in Brooks v. Snow, 313 F.Supp.2d 654 (S.D.Tex.2004). There, the plaintiffs sought a declaration from the court that Treasury Regulation 26 C.F.R. 301.722-1 (listing the grounds authorizing the IRS to settle a tax case) was inconsistent with congressional intent, because the regulation omitted delays caused by the IRS in determining tax liability. Id. at 658-59. The court dismissed their complaint, explaining that they had not "allege[d] they ever submitted any offers-in-compromise and, therefore, they have not upp. 239, 255 (Ct.Cl. 1947) (<HOLDING>). Second, and most crucially, this plaintiff
Holding statements: (A) holding that a refund may include additional taxes paid after the filing of a refund claim so long as the total does not exceed the portion of tax paid prior to the administrative claim (B) holding under section 7422a that the district court lacked jurisdiction over a taxpayers refund claim because the taxpayer failed to file a refund claim before the statute of limitations had run (C) holding that because the amount of the debtors obligation to the government exceeded the amount of their income tax refund the refund did not become property of the estate and could not be exempted (D) holding that a taxpayer only has a refund right after the irs has credited the refund to other underpaid taxes therefore the refund was not part of the bankruptcy estate (E) holding that a subsequent refund request on reassessed taxes was unnecessary as the government already had notice of the plaintiffs claim
[A]: (E)

[Q]: interest of safety and security at the institution. Accordingly, the order of the district court denying Hyde's petition for writ of habeas corpus is affirmed in part and reversed in part. Chief Judge LANSING and Judge PERRY concur. 1 . Roles was addressed in the context of FERPA. However, as we discuss below, there is no distinction between FERPA's compelling govern mental interest standard and that embodied in RLUIPA. 2 .Some states along with the Federal Bureau of Prisons allow sweat lodges and other Native American religious practices at maximum security prisons. See Pounders v. Kempker, 79 Fed. Appx. 941, 943 n. 2 (8th Cir.2003) (noting that Missouri eventually built a sweat lodge at its maximum security Potosi Correctional Center); Allen v. Toombs, 827 F.2d 563 (9th Cir.1987) (<HOLDING>); Morrison v. Cook, 1999 WL 717218, *4 (D.Or.
Holding statements: (A) holding that removal from house arrest and return to general prison population was a matter of inmate classification (B) holding that africanamerican plaintiffs claims that defendants should have known that placing him in a jail with a large population of white inmates put him at risk of being attacked were without merit because the plaintiff had not alleged any specific facts which would show that he was in danger of being assaulted by the other inmates (C) holding that prison conditions are those aspects of prison life affecting the entire prison population (D) recognizing general rule (E) recognizing that general population inmates at oregon maximum security prison were allowed to participate in weekly sweat lodge ceremonies
[A]: (E)

[Q]: sources of its hearsay, this member of the Court sees no reason to deprive them of these opportunities for the sheer sake of expediency. Finally, the Court is far from convinced that it should defer questions of admissibility until all of the government's evidence has been considered on the theory that "the reliability of a particular piece of evidence will generally depend on how it fits within the evidence as a whole." Gov't's Mem. at 3. This suggested approach is a direct inversion of what takes place in any other kind of adjudicative process, where factual findings are made on the basis of admissible evidence, not the other way around. See Concrete Pipe & Prods. of Cal., Inc. v. Constr. Laborers Pension Trust for S. Cal., 508 U.S. 602, 622, 113 S.Ct. 2264, 124 L.Ed.2d 539 (1993) (<HOLDING>). Ultimately, attempting to determine the
Holding statements: (A) holding that the proper standard of proof is preponderance of the evidence (B) holding that the burden of persuasion by a preponderance of the evidence remains with the movant (C) holding that there must be sufficient competent evidence from which the trier of fact could estimate the amount of damages with a reasonable degree of certainty (D) holding that the district court determines the amount of loss under the preponderance of the evidence standard (E) holding that with respect to the preponderance of the evidence standard before any such burden can be satisfied in the first instance the factfinder must evaluate the raw evidence finding it to be sufficiently reliable and sufficiently probative to demonstrate the truth of the asserted proposition with the requisite degree of certainty
[A]:
(E)