Legal Opinion

Howell v. United States

Court of Appeals for the Tenth Circuit

Decided December 29, 1998No. 97-4014PublishedCited by 11 opinions

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

  1. United States v. John A. ChilaCourt of Appeals for the Eleventh Circuit · 1989
  2. John G. Gowan v. United States Department of the Air ForceCourt of Appeals for the Tenth Circuit · 1998
  3. Fred Marvel and Angela Marvel, D/B/A Marvel Photo v. United StatesCourt of Appeals for the Tenth Circuit · 1983
  4. Stallard v. United StatesCourt of Appeals for the Fifth Circuit · 1994
  5. Edward J. Finley, and Counterclaim v. United States of America, and Counterclaim Floyd Johnson, CounterclaimCourt of Appeals for the Tenth Circuit · 1997

2 more not listed; retrieve them via the Exa API.

3Cited by11 opinions

  1. Linda Romano-Murphy v. Commissioner of IRSCourt of Appeals for the Eleventh Circuit · 2016
  2. Dallin v. United StatesUnited States Court of Federal Claims · 2004
  3. Intersport Fashions West, Inc. v. United StatesUnited States Court of Federal Claims · 2008
  4. Smith v. United StatesCourt of Appeals for the Tenth Circuit · 2009
  5. Underberg v. United StatesDistrict Court, D. New Mexico · 2005

6 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API