Legal Opinion
Roland J. Kalb v. United States of America, and Third-Party v.jerome L. Herold, Third-Party
Court of Appeals for the Second Circuit
Decided October 15, 1974No. 741 and 742, Dockets 73-2222 and 73-2256PublishedCited by 144 opinions
1Opinion of the Court
HAYS, Circuit Judge:
In April 1969 the IRS assessed appellants $163,613.35 in penalties pursuant to 26 U.S.C. § 6672 (1970) for failure to collect and pay over to the United States taxes withheld from employees of Herold Radio & Electronics Corp. for various periods in 1959, 1960, and 1961. Appellant Kalb paid part of the assessment and then commenced an action for a refund of the payment. The United States counterclaimed for the unpaid part of the assessment. Later the United States commenced a third-party action against appellant Herold and another officer of Herold Electronics. Herold…
2Cases cited21 opinions
- Fuentes v. ShevinSupreme Court of the United States · 1972
- Phillips v. CommissionerSupreme Court of the United States · 1931
- Robert W. Monday v. United States of America, and Third-Party v. John A. Monday, Third-PartyCourt of Appeals for the Third Circuit · 1970
- Lucas v. Pilliod Lumber Co.Supreme Court of the United States · 1930
- J. A. Newsome, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1970
16 more not listed; retrieve them via the Exa API.
3Cited by144 opinions
- Anthony A. Calderone, Clark Hornbaker, Plaintiffs-Counterclaim Defendants v. United States of America, Defendant-Counter-Claimant-AppellantCourt of Appeals for the Sixth Circuit · 1986
- United States v. Mary Rem, Syma Lichter, and Nathan Hanfling, as Executors of the Estate of Henry Rem, Gerard RemCourt of Appeals for the Second Circuit · 1994
- Mazo v. United StatesCourt of Appeals for the Fifth Circuit · 1979
- Waymon Leon Howard v. United StatesCourt of Appeals for the Fifth Circuit · 1983
- Arnold Hochstein, Counterclaim v. United States of America, CounterclaimCourt of Appeals for the Second Circuit · 1990
139 more not listed; retrieve them via the Exa API.