Abramson v. United States

MEMORANDUM OF DECISION AND ORDER

NEAHER, District Judge.

Plaintiff Gilbert Abramson invoked this Court’s jurisdiction pursuant to 28 U.S.C. § 1346(a)(1) to challenge a penalty tax assessment against him under 26 U.S.C. § 6672, by virtue of his status as Secretary-Treasurer of the now bankrupt Hargil Advertising Associates, Inc. (Hargil). On June 16, 1980 the Internal Revenue Service (IRS) had invoked § 6672 to collect $35,-214.41 plus interest in withheld employee social security and income taxes, which Hargil had not paid for the fourth quarter of 1978 and the first three quarters of 1979. 1

By…