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.
--------
Question: 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

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

Question: Executone Info. Sys., Inc. v. Davis, 26 F.3d 1314, 1320 (5th Cir.1994))). 17 . See Executone, 26 F.3d at 1320 ("We must sustain an arbitration award even if we disagree with the arbitrator's interpretation of the underlying contract as long as the arbitrator's decision 'draws its essence' from the contract." (internal quotation marks and citation omitted)). 18 . See also Parsons & Whittemore, 744 F.2d at 1483-84 (recounting that the arbitration panel awarded postjudgment interest at state statutory rate). 19 . We construe the parties' intentions "generously" to determine whether they agreed to arbitrate a particular issue. See Mitsubishi Motors Corp. v. Soler Chrysler-Plymouth, Inc., 473 U.S. 614, 626, 105 S.Ct. 3346, 87 L.Ed.2d 444 (1985). 20 . Cf. Newmont, 615 F.3d at 1272, 1276 (<HOLDING>). 21 . Riebesell, 586 F.3d at 794;
Holding statements: (A) holding that court should consider issues relating to making and performance of agreement to arbitrate (B) holding that because the parties agreed to arbitrate and both placed the issue before the arbitrator the issue of consolidation was for the arbitrator (C) holding that because the parties agreed to arbitrate the particular issue any doubt about who should decide the consolidation issue was resolved in favor of the arbitrator (D) holding that companys contention that union repudiated the agreement to arbitrate a particular dispute was a matter for the arbitrator and not the court to decide (E) holding that agreement to arbitrate any dispute arising out of contract authorized arbitrator to decide postjudgment interest issues

Answer: holding that court should consider issues relating to making and performance of agreement to arbitrate

Question: 93, 95 (1971) (attorney general, not county attorney, represents state's interests with respect to revocation of drivers' licenses). Because the county attorney did not represent the DOT in the criminal proceedings and had no independent authority, any representation by the county attorney that section 321.209 did not apply to Schumacher is not binding on the DOT. Cf. Bassion, 568 A.2d at 1320 (because department of transportation was not a party to criminal proceeding, any order entered in criminal case concerning the defendant's operating privileges would not be binding on the department). For the same reasons, a county attorney does not have the authority to waive the applicability of section 321.209 as part of plea bargaining in a criminal case. State v. House, 192 N.W.2d at 95 (<HOLDING>); Commonwealth v. Lefever, 533 A.2d 501, 503
Holding statements: (A) holding that officers had reasonable suspicion to conduct a vehicle stop where official license and registration records reflected that the vehicle was registered to a driver with a revoked license (B) holding that a guilty plea to underage drinking could not be withdrawn based on fact defendant was unaware that his drivers license would be suspended because of his conviction as the license suspension was a civil consequence of the conviction (C) holding that county attorney had no authority to agree during plea negotiations that defendants drivers license would not be revoked (D) holding that the county attorney had de facto authority and noting that the objection to the county attorneys authority was first made on appeal (E) holding that district attorney had no power during plea bargaining to bind the state department of transportation to forego license suspension

Answer:
holding that officers had reasonable suspicion to conduct a vehicle stop where official license and registration records reflected that the vehicle was registered to a driver with a revoked license