East Wind Industries, Inc. v. United States

MANSMANN, Circuit Judge:

This appeal arises out of a judgment of the United States District Court for the District of New Jersey granting the Government’s motion for summary judgment and denying the Taxpayers’ cross-motion for summary judgment in their action seeking a refund of tax penalties. The Taxpayers contended before the District Court, as well as on appeal, that reasonable cause existed for the late payment and deposit of employment taxes under 26 U.S.C. §§ 6651(a)(2) and 6656(a), respectively and, therefore, they are entitled to an abatement of the penalties assessed under those…