United States v. Industrial Crane and Manufacturing Corporation

GODBOLD, Circuit Judge:

By a contract executed by Billmeier arid Quarles and dated April 30, 1969, appellant’s sole stockholder, Billmeier, sold his stock in appellant corporation to Quarles. The contract provided that appellant “has assumed a maximum of $7,500” of Billmeier’s potential personal liability as responsible officer of a predecessor corporation for the predecessor’s non-payment of withholding taxes. 1 Appellant was not a party signatory to the contract and did not execute a formal assumption of Billmeier’s liability.

Under date of May 1, 1969, Billmeier entered into an employment…