Definition: 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.
Input: property of the bankruptcy estate vests in the reorganized debtor, a new entity, and administration of the estate ceases." U.S. v. Redmond, 36 B.R. 932, 934 (D.Kan.1984). The duty to pay federal income taxes is tied to the duty to make an income tax return. See Holywell Corporation v. Smith, 503 U.S. 47, 52, 112 S.Ct. 1021, 1024, 117 L.Ed.2d 196 (1992) (citing 26 U.S.C. 6151(a), which provides, in part, "[W]hen a return of tax is required ... the person required to make such return shall ... pay such tax-"). Among the persons required to make returns of income are estates, trusts, and estates of individuals under Chapters 7 or 11 of the Bankruptcy Code. See 26 U.S.C. 6012(a)(3),(a)(4), and (a)(9); see also In re I.J. Knight Realty Corp., 501 F.2d 62, 65 (3d Cir.1974) (<HOLDING>). The "[r]eturns of an estate, trust, or an
Holding statements: (A) holding that punitive damages are excludable from gross income under 26 usc 104a2 (B) holding that the phrase return of income used in 26 usc 6012 is synonymous with the phrase return of tax used in 26 usc 6151 (C) holding that the phrase or ganic diseases of the nervous system contained in 38 usc 11013 was ambiguous because the statute did not define the phrase (D) holding that the possibility of a mistaken understanding of the phrase preponderance of the evidence on the part of the jury is too remote to constitute plain error when counsel gave the jury an accurate explanation of the legal meaning of the phrase in his closing argument and that meaning is consistent with the common understanding of the words in the phrase (E) holding that punitive damages are not awarded on account of personal injuries or sickness pursuant to 26 usc 104a2 and therefore constitute gross income
Output:
holding that punitive damages are excludable from gross income under 26 usc 104a2