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.

[Q]: a “responsible person” under § 6672 in these circumstances. B. Willfulness 1. Standard of Review As with the previous issue, the government asserts that the determination of willfulness under § 6672 is a question of law subject to de novo review, while Bradshaw argues that it is a question of fact on which the district judge’s ruling can not be overturned unless it is clearly erroneous. Some circuits have held that the ultimate issue of willfulness is subject to de novo review. United States v. McCombs, 30 F.3d at 320 (noting, however, that this is a difficult question that, in similar contexts, has divided the courts for over a century); Thibodeau v. United States, 828 F.2d at 1505-07. Our prior decisions have, however, treated this as an issue of fact. See Taylor, 69 F.3d at 417-18 (<HOLDING>); Denbo, 988 F.2d at 1033 (reviewing jury 
 Holding statements: (A) holding that we review for clear error the bankruptcy courts factual findings (B) holding that the district court sitting in review of the decision of the bankruptcy court erred in concluding that plaintiffs failure to pay over taxes was willful because the bankruptcy court had made no findings on willfulness we remanded for bankruptcy court findings (C) holding that 28 usc  1961a applies to bankruptcy court judgments because a bankruptcy court is a unit of the district court (D) holding that bankruptcy court may issue proposed findings and conclusions in a core proceeding over which the bankruptcy court does not have constitutional authority (E) holding that the bankruptcy court has the inherent power to award sanctions for badfaith conduct in a bankruptcy court proceeding
[A]: holding that we review for clear error the bankruptcy courts factual findings


[Q]: If a statement does not contain any expressly exculpatory material, the Government need not produce that statement to the defense. To hold otherwise would impose an insuperable burden on the Government to determine what facially non-exculpatory evidence might possibly be favorable to the accused by inferential reasoning. We are confident that the Supreme Court did not intend the Brady holding to sweep so broadly. United States v. Comosona, 848 F.2d 1110, 1115 (10th Cir.1988); see also Harris v. Kuba, 486 F.3d 1010, 1016 (7th Cir.2007) {“Brady does not require that police officers or prosecutors explore multiple potential inferences to discern whether evidence that is not favorable to a defendant could become favorable.”); United States v. Marrero, 904 F.2d 251, 261 (5th Cir.1990) (<HOLDING>). The Court finds that just such inferential 
 Holding statements: (A) holding that the presentation of a new theory does not constitute the presentation of a new issue on which a jury trial should be granted as of right under  rule 38b (B) holding that there is no constitutional duty to do a better investigation and that a decision not to conduct a more thorough investigation does not invade an accuseds rights (C) holding that the burden is on the plaintiff (D) holding that the burden is upon the state under the applicable federal rules of evidence (E) holding that brady does not place any burden upon the government to conduct a defendants investigation or assist in the presentation of the defenses case
[A]: holding that the presentation of a new theory does not constitute the presentation of a new issue on which a jury trial should be granted as of right under  rule 38b


[Q]: or justify its action. If the aggrieved party is not then satisfied, the matter shall be submitted to the American Arbitration Association for final and mutually binding resolution by it including the award of damages or other relief. Peoples Security, 867 F.2d at 810 n. 1. The court held that this language was broad enough to encompass a claim of fraud in the inducement of the agreement. Id. at 813-14. In so holding, the court reversed the determination by the district court that the arbitration clause in question was not broad enough to cover the fraudulent inducement claim. The Peoples Security court cited with approval several cases from other jurisdictions construing language similar to that contained in the Alamria/Telcor Contract. See e.g., S.A. Mineracao, 745 F.2d at 192 (<HOLDING>) (second alteration in original); Life of 
 Holding statements: (A) holding that the language of the arbitration clause   any controversy or claim arising out of     was broad enough to encompass the plaintiffs claim alleging fraud in the inducement of the contract (B) holding that a clause requiring arbitration wjhenever any question or dispute shall arise or occur under this agreementcontract was sufficiently broad to cover a claim of fraudulent inducement (C) holding that a clause covering any controversy or claim  related directly or indirectly to this agreement was a broad arbitration clause (D) holding that the clause any dispute that shall arise between the parties  with reference to the interpretation of this agreement or their rights with respect to any transaction involved was broad (E) holding that a clause requiring arbitration of any controversy or claim that shall arise out of this agreement or the breach thereof was sufficiently broad to cover a 1934 securities act claim involving fraudulent misrepresentation
[A]:
holding that the language of the arbitration clause   any controversy or claim arising out of     was broad enough to encompass the plaintiffs claim alleging fraud in the inducement of the contract