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:
testified that Gollapudi admitted that he prepared and signed the W-2 forms and that they were false. Additionally, although Gollapudi presented evidence that the withholding amounts were true based on his “gross up” method, the District Court found this theory to be without merit based on the testimony of another IRS agent who demonstrated that no withholding was actually made. Moreover, it was established that the alleged withholding was never submitted to the IRS, but rather, was maintained in Gollapudi’s corporate checking account. Furthermore, Gollapudi’s reliance on Reynolds and Borman is misguided. Both of those cases involved § 7206(1) charges for filing the wrong tax form. Reynolds, 919 F.2d at 437 (“Using the wrong form does not violate § 7206(1).”); Borman, 992 F.2d at 126 (<HOLDING>). Furthermore, in Reynolds, the theory in the 
 Holding statements: (A) holding that materiality is not an element of  1542 because any false statement is sufficient (B) holding that plaintiff failed to prove reasonable reliance on a false statement (C) holding that form 4790 is not an administrative rule but is merely incidental to the statute and regulations and therefore false statements on the form can lead to criminal prosecution (D) holding that filing of improper form is not enough to establish false statement for  72061 purposes (E) holding that a false schedule c is an integral part of a tax return and is incorporated therein by reference thus giving rise to liability under  72061
answer:
(D)


question:
is correct. We will also assume that the court’s erro umed error prejudiced him is that other evidence supports the finding that he was a manager or supervisor of the conspiracy. In the district court, Vasquez did not object to the PSR’s statement that he “recruited Wornick and Sella” into the conspiracy. Although the district court did not explicitly find that Vasquez recruited two of his co-conspirators, “[i]t is the law of this circuit that a failure to object to allegations of fact in a[PSR] admits those facts for sentencing purposes.” United States v. Wade, 458 F.3d 1273, 1277 (11th Cir.2006). And we have held many times that a defendant’s recruitment of co-conspirators supports a § 3B1.1 enhancement. See, e.g., United States v. Thomas, 446 F.3d 1348, 1355 n. 2 (11th Cir.2006) (<HOLDING>); United States v. Ndiaye, 434 F.3d 1270, 1304 
 Holding statements: (A) holding that the district court did not clearly err in finding that the defendant was an organizer leader manager or supervisor under  3bllc in part because the defendant actively recruited two individuals to transport drugs (B) holding that the district court did not clearly err in finding that the defendant was a manager or supervisor under  3bllb in part because he recruited accomplices (C) holding that trial court did not err (D) holding that a trial court did not clearly err in finding that an attorney fees clause materially altered a contract (E) holding that the district court did not clearly err in finding that the defendant was an organizer or leader under  3blla in part because he recruited coconspirators
answer:
(E)


question:
to allow plaintiff to add a claim for breach of contract, which had a fifteen-year statute of limitations. The action was brought outside the one-year but within the fifteen-year statute. On appeal, the appellate court reviewed the Puerto Rican statutes pertaining to conversion and breach of contract, decided that the district court did not err in refusing to allow plaintiff to add the contract claim, and concluded that plaintiffs action still would have been time-barred because “given the applicability of COGSA [to the foreign bill of lading at issue], [plaintiff] cannot circumvent COGSA’s operation by couching its complaint in terms of conversion or breach of contract.” Barretto Peat, 896 F.2d at 661 (citing Miller Export Corp. v. Hellenic Lines, Ltd., 534 F.Supp. 707 (S.D.N.Y.1982) (<HOLDING>)). In an Eleventh Circuit ease, Generali v. 
 Holding statements: (A) holding that a failure to maintain sufficient internal controls to avoid fraud is  indicative of scienter (B) holding that cogsa controls shippers claim against carrier even though the purported fraud or negligence is alleged to have occurred prior to loading or subsequent to discharge (C) holding that the right to discharge factor supported contractor status even though the company was only required to provide thirty days notice to discharge a motor carrier (D) holding that  65551 another part of the medical liability act applied to the plaintiffs claim of fraud against a defendant physician because the alleged fraud occurred during preoperative doctorpatient consultations (E) holding that a plaintiff has a duty to plead the date of discovery of fraud where the alleged fraud apparently occurred at a remote time
answer:

(B)