Peterson v. United States

FINDINGS OF FACT AND CONCLUSIONS OF LAW

SHADUR, District Judge.

This action was begun and has continued in the typical pattern followed by lawsuits dealing with withholding taxes: Robert Peterson (“Robert”) initially sued for a refund of the small amount of such taxes that he had paid, and the United States then counterclaimed against him and his brother John Peterson (“John”) for the much larger amount of withholding taxes unpaid by the brothers’ corporation (asserting that each was a “responsible person” within the meaning of the relevant statute).

This Court conducted a bench trial to deal…