TASK DEFINITION: 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.
PROBLEM: 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

SOLUTION: holding that we review for clear error the bankruptcy courts factual findings

PROBLEM: commercial, including ... [any maritime contract evidencing a transaction involving commerce], falls under the Convention. An agreement or award arising out of such a relationship which is entirely between citizens of the United States shall be deemed not to fall under the Convention unless that relationship involves property located abroad, envisages performance or enforcement abroad, or has some other reasonable relation with one or more foreign states. For the purpose of this section a corporation is a citizen of the United States if it is incorporated or has its principal place of business in the United States. 9 U.S.C. §§ 201 and 202; see also 9 U.S.C. § 2. A seaman’s contract that contains an agreement to arbitrate generally falls under the convention. Bautista, 396 F.3d at 1299 (<HOLDING>) (citing Francisco v. STOLT ACHIEVEMENT MT, 293 
 Holding statements: (A) holding that the court was not bound by the parties agreement that contracts were unambiguous and holding that contracts were ambiguous (B) holding implied covenant of good faith and fair dealing found in some commercial contracts does not extend to atwill employment contracts (C) holding that contracts for an indefinite period are excluded from the statutes coverage (D) holding that at will contracts of employment are subject to tortious interference with contracts claims (E) holding that the convention and us implementing statutes do not recognize an exception for seaman employment contracts and concluding that such contracts are commercial for purposes of same

SOLUTION: holding that the court was not bound by the parties agreement that contracts were unambiguous and holding that contracts were ambiguous

PROBLEM: any records it has linking Gordon, Langford, or Ford to its investigation into the four murders, or it must follow the normal practice in FOIA cases of identifying the records it has withheld and stating its reasons for doing so.” Id. at 1182. Although the plaintiff maintains a claim of innocence, unlike in Roth, any public interest in knowing whether the defendant withholds information that could corroborate that claim does not outweigh the privacy interests at stake. c. Balancing the Privacy and Public Interests If there is a privacy interest in the requested materials and no public interest in disclosure, “[w]e need rcement agents. However, individuals mentioned in law enforcement files also have a recognized privacy interest. See Spirko v. USPS, 147 F.3d 992, 999 (D.C.Cir.1998) (<HOLDING>). And plaintiff has failed to show how the 
 Holding statements: (A) holding that the privacy interests of the employee police officers did not exceed the publics right to know (B) recognizing the strong privacy interests of the suspects and law enforcement officers identified in the withheld documents (C) holding that exemption 7c protects the privacy interests of all persons mentioned in law enforcement records whether they be investigators suspects witnesses or informants and their names are generally exempt from disclosure (D) recognizing the privacy interests when requested documents neither confirm nor refute the plaintiffs allegations of government misconduct (E) holding that exemption 7c protects the privacy interests of all persons mentioned in law enforcement records whether they be investigators suspects witnesses or informants and their names are generally exempt from disclosure  

SOLUTION:
holding that the privacy interests of the employee police officers did not exceed the publics right to know