Legal Opinion
Charles E. Bradley and David P. Agnew v. United States
Court of Appeals for the Second Circuit
Decided June 24, 1991No. 550, Docket 90-6206PublishedCited by 20 opinions
1Opinion of the Court
MAHONEY, Circuit Judge:
The Internal Revenue Code requires employers to deduct income and social security taxes from their employees’ wages, and to hold these sums in trust for the United States. 26 U.S.C. §§ 3102(a), 3402(a), 7501(a) (1988). In addition, 26 U.S.C. § 6672(a) (1988) 1 provides that officers or employees of a corporation who willfully fail to collect and pay over these “trust fund taxes” are liable to a penalty equal to the amount of the delinquent taxes. 26 U.S.C. § 6601(e)(2)(A) (1988) 2 imposes interest on assessable penalties.
This appeal presents the question whether two…
2Cases cited12 opinions
- In Re Joanne G. Burns, Debtor. Joanne G. Burns v. United States of America, Acting by and Through the Internal Revenue ServiceCourt of Appeals for the Eleventh Circuit · 1989
- Arnold Hochstein, Counterclaim v. United States of America, CounterclaimCourt of Appeals for the Second Circuit · 1990
- Ben D. Spivak and David S. Shapiro v. United StatesCourt of Appeals for the Second Circuit · 1967
- Empire Volkswagen Inc. v. World-Wide Volkswagen Corp.Court of Appeals for the Second Circuit · 1987
- Hanna v. United States (In re Hanna)Court of Appeals for the Eighth Circuit · 1989
7 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Great Lakes Higher Education Corp. v. Pardee (In Re Pardee)United States Bankruptcy Appellate Panel for the Ninth Circuit · 1998
- Aleta Chappelle v. Beacon Communications Corp., Beacon Films, Inc., Ghiznost Productions, Inc. And Gregory BrownCourt of Appeals for the Second Circuit · 1996
- 32 Collier bankr.cas.2d 38, Bankr. L. Rep. P 77,567 in Re Salvatore J. Mazzeo, Debtor. Salvatore J. Mazzeo v. United States of America and New York State, New York State Department of Taxation and Finance, Creditor, Marianne De Rosa, TrusteeCourt of Appeals for the Second Circuit · 1997
- Douglas A. Olsen v. United StatesCourt of Appeals for the Eighth Circuit · 1991
- Leeper v. Pennsylvania Higher Education Assistance AgencyCourt of Appeals for the Third Circuit · 1995
15 more not listed; retrieve them via the Exa API.