W. Eugene Dillard v. George D. Patterson, District Director of Internal Revenue for District of Alabama, and United States of America, Intervenor

GEWIN, Circuit Judge.

This case involves the imposition of a penalty on W. Eugene Dillard in an amount equal to the withholding and F.I.C.A. taxes withheld from employees of Bessemer Materials Company (Bessemer), an Alabama corporation, now a bankrupt, as provided and authorized by § 6672 of the Internal Revenue Code of 1954. 1 Dillard was President of the corporation and makes no point about the duty imposed on him as the responsible officer of the corporation, and does not question the liability of the corporation for the taxes involved. He does contest the imposition of the penalty. The tax…