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: on the conditions stated in the publicly-filed limited partnership certificate. We affirm the appellants' liability under 106(l)(b). The certificates of limited partnership for TSG, TMG, and TSG 80 all state that, if necessary to satisfy the partnership's recourse obligations, each limited partner has agreed, upon demand, to make an additional capital contribution of up to three times the limited partner's original investment. These certificates were recorded publicly in New York County. Accordingly, the capital of the Limited Partnerships upon which creditors properly could rely included the limited partners' stated ob ligation to make additional capital contributions. See Arno Management Corp. v. 115 East 69th Assocs., 173 A.D.2d 258, 260, 569 N.Y.S.2d 656, 657 (1st Dept.1991) (<HOLDING>). Section 106(l)(b) explicitly provides a means
Holding statements: (A) holding that limited partner does not have standing to sue for injuries to partnership that merely diminish value of that partners interest (B) holding that appellate jurisdiction is limited to the issues contained in the certificate of appealability (C) recognizing partnership by estoppel only with respect to claims by persons who have reasonably relied upon outward representations of partnership (D) recognizing that same principle applies where defendant is general partner of limited partnership which in turn is general partner of limited partnership with contacts with state (E) holding that the information contained in the certificate of limited partnership binds the partnership and the partners with respect to third parties
Example Output: holding that limited partner does not have standing to sue for injuries to partnership that merely diminish value of that partners interest

Example Input: unless the controlling person had no knowledge of or reasonable grounds to believe in the existence of the facts by reason of which the liability of the controlled person is alleged to exist. 15 U.S.C. 77o. 6 .Section 20(a) of the 1934 Act provides: Every person who, directly or indirectly, controls any person liable under any provision of this chapter or of any rule or regulation thereunder shall also be liable jointly and severally with and to the same extent as such controlled person to any person to whom such controlled person is liable, unless the controlling person acted in good faith and did not directly or indirectly induce the act or acts F.2d 873, 881 (7th Cir.1992) (applying Eighth Circuit's test) with Brown v. Enstar Group, Inc., 84 F.3d 393, 396 & n. 6 (11th Cir. 1996) (<HOLDING>), cert, denied, U.S. , 117 S.Ct. 950, 136
Holding statements: (A) holding a defendant is liable as a control person if the defendant had the power to control the general affairs of the entity primarily liable at the time the entity violated the securities laws but declining to decide whether power to control means simply abstract power to control or actual exercise of the power to control internal quotations omitted (B) holding authority to control limits duty to control (C) holding that to establish a prima facie case of control person liability a plaintiff must establish that the alleged control person actually participated in ie exercised control over the operations of the primary violator in general internal quotations omitted (D) recognizing that court has inherent power to control the judicial business before it (E) recognizing power of district courts to control movement of cases from filing to final disposition
Example Output:
holding authority to control limits duty to control