instruction:
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.
question:
Over Plaintiffs' Refund Claim. The June 4, 2009 Second Amended Complaint also could be construed as alleging a claim for tax refund, because Plaintiffs request the return of taxes that they allegedly paid. Sec. Am. Compl. at 1-2. The court, however, does not have jurisdiction over this claim, because Plaintiffs have failed to pay the taxes owed in full. 26 U.S.C. 6511(a). Plaintiffs insist that they fully paid the taxes in intiffs' Takings Claim. Although Plaintiffs also argue the court has jurisdiction "as described in 28 U.S.C. 1491, for a claim for just compensation for the taking of property [ ] by the government," as a matter of law, tax collection is not a cognizable taking under the Fifth Amendment. U.S. Shoe Corp. v. United States, 296 F.3d 1378, 1383 (Fed.Cir.2002) (<HOLDING>). As the United States Court of Federal Claims
Holding statements: (A) holding unemployment taxes accrued when employees were terminated not when the amount of compensation taxes are determinable (B) holding that taxes are not private property that can be physically taken by the government (C) holding that taxes were a claim against the estate that had to be filed in probate court thus reversing an order requiring heirs to pay taxes on estate property because the district court did not have jurisdiction (D) holding that when federal government acquires property through condemnation it must account for state and local property taxes interest and penalties (E) holding petitioner could not deduct real estate taxes imposed on property he did not own because these taxes were not imposed on him
answer:
(B)

question:
S. Sprouse Residuary Trust, which is a named defendant in this action. For the sake of simplicity, we will refer only to Mr. Sprouse in this opinion. 4 .Ms. Bagwell, who is not a lawyer, also testified that she thought that the original five-year lease was on "a year[-]to[-]year basis." 5 . Mr. Sprouse did not take issue with the $534 award for the damage to Mr. Ellis's corn crop. 6 . See also 2 Friedman on Leases 14.301, at 915 (noting that payment of increased rent under an option constitutes an acceptance of the option). 7 . Painter v. Town of Groveland, 79 So.2d 765, 767 (Fla.1955) (finding such a presumption contrary to statute); Branagen v. Winders & Alm, 194 Iowa 461, 187 N.W. 440, 440-41 (Iowa 1922); Schiltz v. Teledirect Int'l, Inc., 524 N.W.2d 671, 674 (Iowa Ct.App.1994) (<HOLDING>); Elec. Sales Eng'rs, Inc. v. Urban Renewal &
Holding statements: (A) holding there was no renewal but finding estoppel on the part of the landlord (B) holding that the district courts finding of no discrimination under title vii was not clearly erroneous because the finding was supported by the record (C) holding that the district courts finding of no discrimination was not clearly erroneous because the finding was supported by the record (D) recognizing the abuse of discretion standard and the requirement of evidentiary support for a finding of estoppel (E) holding that estoppel was a question of fact
answer:
(A)

question:
property are merely a proposal that may never come to fruition, the Kolbs cannot recover for a present taking. The City bases its argument on case law stating, "future plans which might result in a future taking are merely 'future prospects' and, as such, cannot constitute a taking." Hubler v. City of Corpus Christi, 564 S.W.2d 816, 821 (Tex.Civ.App.Corpus Christi 1978, writ refd n.r.e.). Further, "the announcement of a projected public improvement together with preparation of plans and maps showing the property in question within the limits of the project, without any interference with the landowner's use, does not constitute a present taking." Id. at 822. Here, however, the City has directly infringed upon the owner's current use of the property. See Westgate, 843 S.W.2d at 453 (<HOLDING>). We find, therefore, that the Kolbs have
Holding statements: (A) holding that the trial court was allowed to consider for the purpose of determining just compensation in a condemnation action expert testimony regarding whether the owner of the condemned property would have received permits to develop wetlands existing on the property (B) holding that there is no right to monetary compensation for a regulatory taking in an inverse condemnation action (C) holding that in condemnation proceedings the landowner has the burden of establishing the value of the property (D) holding that property owner still has relief in the form of the return of his property though condemnation was complete and a highway was constructed across the property (E) recognizing that publicly targeting a property for condemnation resulting in economic damage to the owner generally does not give rise to an inverse condemnation cause of action unless there is some direct restriction on use of the property
answer:
(E)