United States v. Barry J. Hodgekins
Court of Appeals for the Seventh Circuit
1Opinion of the Court
MANION, Circuit Judge.
Barry J. Hodgekins became the treasurer of Josam Manufacturing Co., Inc., in December 1984. In August 1985 the company went bankrupt. The Internal Revenue Service (IRS) then assessed tax penalties in excess of $800,000 against Hodgekins under 26 U.S.C. § 6672 for Josam’s failure to pay withholding taxes. Hodgekins filed a protest to this proposed assessment. The IRS agreed to close the ease if Hodgekins executed a waiver of the statute of limitations, which allowed the government to reopen the case without the bar of the statute of limitations “in the event refund…
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