Legal Opinion

Waterhouse v. United States

United States Court of Federal Claims

Decided July 23, 2015No. 12-718TPublishedCited by 3 opinions

1Opinion of the Court

26 U.S.C. § 6672; Failure to Pay Tax; Responsible Person; Willful Conduct; Liability for Penalty

TRIAL OPINION

FIRESTONE, Judge

In this case, plaintiff Douglas Waterhouse (“Mi-. Waterhouse”) seeks a refund of trust fund recovery penalties assessed and partially paid for employment taxes owed to the United States (“the government”) by Skyline Contract Glass, Inc. (“Skyline”). The issue in this case is whether it was proper for the Internal Revenue Service (“IRS”) to assess Mr. Waterhouse with tax penalties for his role in Skyline’s failure to pay over to the government the taxes it had withheld…

2Cases cited26 opinions

  1. Slodov v. United StatesSupreme Court of the United States · 1978
  2. Robert W. Monday v. United States of America, and Third-Party v. John A. Monday, Third-PartyCourt of Appeals for the Third Circuit · 1970
  3. J. A. Newsome, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1970
  4. Donald R. Ferguson v. United States v. Richard Musal, Third Party Nicholas P. Miller, Third PartyCourt of Appeals for the Third Circuit · 2007
  5. Dudley J. Godfrey, Jr., Appellant/cross-Appellee v. United States, Appellee/cross-AppellantCourt of Appeals for the Federal Circuit · 1984

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3Cited by3 opinions

  1. Noffke v. United StatesUnited States Court of Federal Claims · 2016
  2. Rosenheim v. United StatesUnited States Court of Federal Claims · 2022
  3. Warnement v. United StatesUnited States Court of Federal Claims · 2025

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