Legal Opinion

Stephen R. Rykoff, Plaintiff-Counter-Defendant-Appellee v. United States of America, Defendant-Counterclaimant-Appellant

Court of Appeals for the Ninth Circuit

Decided November 14, 1994No. 93-55363PublishedCited by 22 opinions

1Opinion of the Court

BOOCHEVER, Circuit Judge:

The United States appeals the district court’s judgment that Stephen Rykoff did not act “willfully,” within the meaning of 26 U.S.C. § 6672, in failing to pay delinquent withholding taxes during the period beginning February 12, 1982, until his resignation on March 18, 1982. We affirm.

BACKGROUND

Stephen R. Rykoff (“Rykoff’) was President of Fox Drilling Company (“Fox”). Fox was owned equally by Rykoff and Jason Fox, who was the company’s CEO and Chairman of the Board.

Toward the end of 1981 and the beginning of 1982, Fox began to experience financial difficulties. Fox…

2Cases cited11 opinions

  1. United States v. Hector Martin RamosCourt of Appeals for the Ninth Circuit · 1991
  2. Joseph F. Purcell, Plaintiff-Counter-Claim-Defendant-Appellant v. United States of America, Defendant-Counter-Claimant-AppelleeCourt of Appeals for the Ninth Circuit · 1993
  3. Wallace L. Sorenson v. United StatesCourt of Appeals for the Ninth Circuit · 1975
  4. Edwin A. And Pauline Teel v. United StatesCourt of Appeals for the Ninth Circuit · 1976
  5. Robert G. Dudley v. United StatesCourt of Appeals for the Ninth Circuit · 1970

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

3Cited by22 opinions

  1. Edward J. Finley, and Counterclaim v. United States of America, and Counterclaim Floyd Johnson, CounterclaimCourt of Appeals for the Tenth Circuit · 1997
  2. J. Larry Bradshaw, Plaintiff-Counterclaim v. United States of America, Defendant-Counterclaimant-AppellantCourt of Appeals for the Tenth Circuit · 1996
  3. Abel v. United States (In Re Abel)District Court, E.D. Pennsylvania · 1996
  4. Utah State Tax Commission v. StevensonUtah Supreme Court · 2006
  5. United States v. HorowitzDistrict Court, D. Maryland · 2019

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

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