Howell v. United States
Court of Appeals for the Tenth Circuit
1Opinion of the Court
SEYMOUR, Chief Judge.
The Government, appeals the district court’s grant of judgment as a matter of law in favor of Edward B. Rogers. The court’s ruling was based on its conclusion that the assessment of a penalty under I.R.C. § 6672 against Mr. Rogers for willful failure to pay over trust fund taxes was invalid because the Government had not provided Mr. Rogers with information as required by I.R.C. § 6203 and 26 C.F.R. § 301.6203-1. The Government also contends that Mr. Rogers’ failure to pay the funds over was willful as a matter of law. We reverse the court’s ruling that the assessment was…
2Cases cited7 opinions
- United States v. John A. ChilaCourt of Appeals for the Eleventh Circuit · 1989
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- Fred Marvel and Angela Marvel, D/B/A Marvel Photo v. United StatesCourt of Appeals for the Tenth Circuit · 1983
- Stallard v. United StatesCourt of Appeals for the Fifth Circuit · 1994
- Edward J. Finley, and Counterclaim v. United States of America, and Counterclaim Floyd Johnson, CounterclaimCourt of Appeals for the Tenth Circuit · 1997
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