Robert L. Cash and Evelyn L. Cash v. United States of America, Defendant-Counter v. Randall C. Block, Counter

W. EUGENE DAVIS, Circuit Judge:

Taxpayers appeal the district court’s adverse judgment. They argue that the Internal Revenue Service’s levy on accounts receivable of LTS Optical, Inc. (the taxpayers’ corporation) satisfied the corporation’s tax liability, and thereby relieved taxpayers of any liability under § 6672 of the Internal Revenue Code. The United States challenges the taxpayers’ standing to raise this claim. We affirm on the merits.

I

LTS Optical, Inc. (LTS) was formed as a Texas corporation in late 1983 with headquarters in Lubbock, Texas. The corporation operated six wholesale optical…