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.

Example Input: 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
Example Output: holding that we review for clear error the bankruptcy courts factual findings

Example Input: to obtain the benefit of the bond, for which it paid a significant premium, only through legal action. Accordingly, Olympic Steamship applies here. Colorado Structures, 125 Wn. App. at 928 (emphasis added) (footnote omitted). We agree. ¶27 Lastly, in McGreevy, where this court awarded reasonable attorney fees in addition to the limits of the insurance policy, we reasoned, “when an insurer unsuccessfully contests coverage, it has placed its interests above the insured. Our decision in Olympic Steamship remedies this inequity by requiring that the insured be made whole.” McGreevy, 128 Wn.2d at 39-40. Likewise, West placed “its interests” above that of Structures. Id. Structures should be awarded attorney fees under Olympic Steamship, so as to be made “whole.” Dayton, 124 Wn.2d at 280 (<HOLDING>)- Without the application of Olympic Steamship 
 Holding statements: (A) holding the contract was not authorized by law (B) recognizing that under georgia law attorneys fees are allowed where authorized by statute or contract (C) holding because an award of attorney fees is discretionary court may consider attorney fees in relation to the underlying equities in the case (D) holding that an award of attorney fees was authorized by ocga  13111 a 3 when the requirements of that statute were satisfied (E) holding that a court has power to award attorney fees when authorized by contract statute or recognized ground of equity
Example Output: holding the contract was not authorized by law

Example Input: denial of his motions in Leo, Mr. Leo filed his second suit in the Kansas federal district court (No. 10-2495-JTM), in which he used the aforementioned 70,000 word opening brief/“Supporting Analysis” as his complaint. In a memorandum and order dated March 22, 2011, 2011 WL 1097759, the district court concluded that Mr. Leo’s second suit was barred by the doctrine of res judicata based on the earlier suit and granted Garmin’s motion to dismiss. In the same order, the court denied Mr. Leo’s motion for the entry of a default judgment against Garmin and granted Garmin’s request for sanctions. In a subsequent memorandum and order dated April 15, 2011, 2011 WL 1457937, the district court awarded Garmin $ Practice and Procedure § 4433, at 78-85 (2d ed.2 , 425 F.3d 836, 840-41 (10th Cir.2005) (<HOLDING>). We nonetheless have examined each of the 
 Holding statements: (A) holding that although pro se briefs are liberally construed even pro se litigants must brief arguments in order to preserve them (B) holding that pro se pleadings are to be liberally construed (C) holding that although pro se litigants are entitled to liberal construction of their pleadings pro se litigants must follow procedural rules (D) holding that although a pro se litigants pleadings are construed liberally a pro se litigant must still follow the same rules that govern other litigants including the requirement of constructing and supporting arguments with legal authority (E) holding that pro se litigants must follow the kentucky rules of civil procedure
Example Output:
holding that although pro se briefs are liberally construed even pro se litigants must brief arguments in order to preserve them