Legal Opinion
John T. Kennedy v. United States of America, Third Party v. Harold C. Gatewood, Third Party
Court of Appeals for the Third Circuit
Decided June 8, 1992No. 91-1657PublishedCited by 95 opinions
1Opinion of the Court
HARLINGTON WOOD, Jr., Circuit Judge.
The Internal Revenue Service assessed a 100-percent penalty against Harold C. Gatewood and John T. Kennedy as responsible persons of a corporation that failed to pay over federal withholding taxes from employee wages. As a result of a miscalculation, an Internal Revenue Service agent represented to Gatewood’s attorney that Gatewood and Kennedy owed a lesser amount of taxes than the government now demands. Gatewood and Kennedy paid the lesser amount, but they refused to pay the total amount of the corrected assessment to the IRS. The government pursued its…
2Cases cited12 opinions
- Heckler v. Community Health Services of Crawford County, Inc.Supreme Court of the United States · 1984
- Office of Personnel Management v. RichmondSupreme Court of the United States · 1990
- Schweiker v. HansenSupreme Court of the United States · 1981
- Michele Portmann, Doing Business as Grafica, an Individual v. United StatesCourt of Appeals for the Seventh Circuit · 1982
- Orris C. Ruth v. United StatesCourt of Appeals for the Seventh Circuit · 1987
7 more not listed; retrieve them via the Exa API.
3Cited by95 opinions
- Cincinnati Insurance Company v. Flanders Electric Motor Service, IncorporatedCourt of Appeals for the Seventh Circuit · 1994
- Joselito Vitug v. Multistate Tax Commission, Dan R. Bucks, as Executive Director, Les Koenig, as Director of AuditCourt of Appeals for the Seventh Circuit · 1996
- Ralph Condo v. Sysco CorporationCourt of Appeals for the Seventh Circuit · 1993
- United States of America, United States of America, State of Louisiana, Intervenor-Appellee v. Marine Shale Processors, Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1996
- Eldon D. And Kathy A. Anthony v. United StatesCourt of Appeals for the Tenth Circuit · 1993
90 more not listed; retrieve them via the Exa API.