Bellovin v. United States

MEMORANDUM OF DECISION AND ORDER

SPATT, District Judge.

In 1993, the Internal Revenue Service assessed civil penalties, pursuant to § 6672 the Internal Revenue Code (26 U.S.C. § 6672), against Myron Bellovin, John J. Schramm, Robert B. Smith, and John Calderale upon a determination that each was a “responsible person” who willfully failed to collect, trustfully account for, and pay over withheld income taxes and Federal Insurance Contributions Act taxes due and owing from two corporations, Advanced Pipeline Technologies, Inc. (“APT”), and Real Time Systems, Inc. (“Real Time”). Bellovin was the…