Detailed Instructions: 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.
Q: fails to state a claim. 26 U.S.C. 7433(a) provides, in pertinent part, that: If, in connection with any collection of Federal tax with respect to a taxpayer, any officer or employee of the Internal Revenue Service recklessly or intentionally, or by reason of negligence, disregards any provision of this title, or any regulation promulgated under this title, such taxpayer may bring a civil action for damages against the United States in a district court of the United States. Defendant does not allege any violation of the tax code or tax regulation. Under 26 U.S.C. 6672 the Government has discretion as to those from whom it chooses to collect 6672 penalties from. United States v. Pomponio, 635 F.2d 293, 298 (4th Cir.1980); United States v. Pepperman, 976 F.2d 123, 127 (3d Cir.1992) (<HOLDING>). The fact that the IRS has discretion in this
Holding statements: (A) holding that 9613f1 is the exclusive vehicle for responsible parties to obtain contribution from other responsible parties (B) recognizing that where plaintiff is from the forum state and defendant is from an alternate forum each forum can claim a connection to one of the parties (C) holding that the government was not responsible for delay from withdrawal of guilty plea (D) holding that payments from a tortfeasors insurer are not from a collateral source because they stem directly from the tortfeasor (E) recognizing that the government can choose to collect unpaid taxes from corporate employer each responsible person or entirely from one source
A:
(E)