Given the task definition and input, reply with output. 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.

significant understatements of liability totaling over $1 million. Accordingly, the court concludes that defendant is subject to penalty under I.R.C. 6694. IV. CLAIM FOR INJUNCTIVE RELIEF UNDER I.R.C. 7402 In addition to the injunctions sought under I.R.C. 7407 and 7408, the Government also seeks an injunction pursuant to I.R.C. 7402. This statute grants the district courts of the United States the authority "to render such judgments and decrees as may be necessary or appropriate for the enforcement of the internal revenue laws." As set out above, the conduct of defendant has resulted, inter alia, in significant understatements of tax liability and, consequently, is subject to an injunction under I.R.C. 7402. See United States v. Cohen, 222 F.R.D. 652, 657 (W.D.Wash.2004) (<HOLDING>); United States v. Franchi, 756 F.Supp. 889,
Holding statements: (A) holding property lien for nonpayment of sales tax was beyond boroughs authority to collect sales tax (B) holding that us was entitled to injunction under 7402 for defendants provisions of false and fraudulent tax advice through his website and his sales of forms and documents that result in substantial understatements tax liabilities (C) holding that the essential purpose of use tax is the recoupment of lost sales tax revenue (D) holding that 1983 is not an exception to the state tax injunction act (E) holding that plaintiffs who received fraudulent tax advice and acted in reliance on the advice though only alleging a future risk of being assessed penalties for acting on the advice had alleged an injuiyinfact
(B)