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.

Ex 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

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

Ex Input:
" Boone v. Commonwealth, 14 Va.App. 130, 133, 415 S.E.2d 250, 251 (1992). "A battery is an unlawful touching of another.... Whether a touching is a battery depends on the intent of the actor, not on the force applied." Adams v. Commonwealth, 33 Va.App. 463, 468-69, 534 S.E.2d 347, 350 (2000) (citation omitted). " '[T]he slightest touching of another ... if done in a rude, insolent, or angry manner, constitutes a battery for which the law affords redress.' " Id. at 469, 534 S.E.2d at 350 (citation omitted). Accordingly, where Vaughn claims he only intended to scare Robinson and did not intend to shoot or wound him, Vaughn would not be entitled, in my opinion, to have the jury instructed on assault and battery. See Wynn v. Commonwealth, 5 Va.App. 283, 292, 362 S.E.2d 193, 198 (1987) (<HOLDING>). A second theory supported by the evidence is
Holding statements: (A) holding that shooting at a person intending only to scare the person where no touching or wounding occurs supports instructing the jury on simple assault (B) holding that simple assault includes urinating on another (C) holding with no analysis that any person or organization who may be legally liable therefor applies to a person legally liable for injuries caused by an accident 4 when under the facts of the case the only person to whom the clause could have applied was a tortfeasor (D) holding that punching another person is a statutory assault (E) holding simple assault is a lesser included offense of recklessly endangering another person

Ex Output:
holding that simple assault includes urinating on another

Ex Input:
petition if this Court eventually affirmed the grant of visitation rights to Vest, I find the quoted passage to be possible support for granting Vest visitation rights, rather than for denying them. 2 . My preference would be to remand to the children's court for further findings on the issue of visitation. See State ex rel. Human Servs. Dep't v. Coleman, 104 N.M. 500, 505, 723 P.2d 971, 976 (Ct.App.1986). As already noted, the children's court's inquiry into this issue was too limited in scope. Additionally, there has been a significant lapse of time since the children's court's determination. This appellate delay may have had a crucial effect on the issues before the children's court. See generally State ex rel. Juvenile Dep't v. Geist, 310 Or. 176, 796 P.2d 1193, 1200-01 (1990) (<HOLDING>). Because the paramount concern here is the
Holding statements: (A) recognizing that the department is required to present clear and convincing evidence to support termination of a parents parental rights (B) holding parental rights are constitutionally protected fundamental interest (C) recognizing this substantial interest in context of termination of parental rights (D) recognizing that protracted litigation regarding parental rights is detrimental to children (E) holding that evidence did not support termination of parental rights to two children despite mothers prior conviction for killing her stepchild

Ex Output:
recognizing that the department is required to present clear and convincing evidence to support termination of a parents parental rights