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: Consider 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

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

Input: Consider Input: allege no physical harm resulting from Wells Fargo's voluntary undertaking of services. See Torrington Co. v. Stutzman, 46 S.W.3d 829, 838 (Tex.2000) ("One who undertakes, gratuitously or for consideration, to render services to another which he should recognize as necessary for the protection of the other's person or things, is subject to liability to the other for physical harm resulting from his failure to exercise reasonable care to perform his undertaking, if (a) his failure to exercise such care increases the risk of such harm, or (b) the harm is suffered because of the other's reliance upon the undertaking." (quoting Restatement (Second) of Torts 323 (1965))) (emphasis added); see also Vodicka v. Lahr, No. 03-10-00126-CV, 2012 WL 2075713, at *6 (Tex.Ct.App. Jun. 6, 2012) (<HOLDING>). CONCLUSION For the foregoing reasons, we
Holding statements: (A) holding that plaintiffs failed to state a claim for negligent undertaking because that tort requires proof of physical harm resulting from failure to exercise reasonable care in rendering services to another and plaintiffs had alleged only economic harm (B) holding that economic loss rule precluded the plaintiffs tort claims because they only alleged injuries to the subject of the contract itself (C) holding that plaintiffs who alleged a subjective chill of their first amendment rights failed to establish specific present objective harm or a threat of specific future harm (D) holding that section 4149 did not apply to the plaintiffs state law claims of breach of duty to protect foster care children from harm and of negligent supervision negligent entrustment and negligent failure to warn (E) holding that the plaintiffs stated a claim for conspiracy because they alleged an actionable tort

Output: holding that economic loss rule precluded the plaintiffs tort claims because they only alleged injuries to the subject of the contract itself

Input: Consider Input: with Rule 11 (c) (1) as to each individual charge for which a plea of guilty is offered." (Emphasis added.) Additionally, a review of other states with rules of practice similar to 39-19 reveals that they also require the court, when accepting pleas of guilty or nolo contendere, to ensure that the defendant understands the nature of each charge and the maximum penalty associated therewith, in addition to the maximum possible consecutive sentence when there are multiple charges. These states also consider this information to be mandatory, and, when the failure to inform on each of these direct consequences is raised via a motion to withdraw a plea before the trial court imposes sentencing, the withdrawal must be permitted. See, e.g., Wells v. State, 396 A.2d 161, 162 (Del. 1978) (<HOLDING>); People v. Flannigan, 131 Ill. App. 2d 1059,
Holding statements: (A) holding that conspiracy to commit a particular substantive offense cannot exist without at least the degree of criminal intent necessary for the substantive offense itself internal quotation marks omitted (B) holding statutory maximum for prior conviction is the potential maximum sentence defined by the applicable state criminal statute not the maximum sentence which could have been imposed against the particular defendant according to the states sentencing guidelines (C) holding that to determine whether a north carolina conviction for a crime is punishable by a prison term exceeding one year a court is to consider the maximum aggravated sentence that could be imposed for that crime upon a defendant with the worst possible criminal history internal quotation marks and emphasis omitted (D) recognizing district courts broad discretion to impose prison term up to the statutory maximum for violations of supervised release internal quotation marks omitted (E) holding that the maximum possible sentence provided by law for conviction of the offense charged is the most important consequence of the plea internal quotation marks omitted
Output: holding that conspiracy to commit a particular substantive offense cannot exist without at least the degree of criminal intent necessary for the substantive offense itself internal quotation marks omitted