Legal Opinion
United States v. Security Pacific Business Credit, Inc.
Court of Appeals for the Seventh Circuit
Decided February 12, 1992No. 90-2624PublishedCited by 14 opinions
1Opinion of the Court
POSNER, Circuit Judge.
We must try to make sense of two overlapping tax statutes that lack any implicit or explicit cross-reference — statutes that exist as it were in a state of mutual oblivion. The earlier enacted one, 26 U.S.C. § 6672(a), imposes “a penalty equal to the total amount of the tax evaded, or not collected, or not accounted for and paid over” on anyone who, being “required to collect, truthfully account for, and pay over any tax,” willfully fails to do so. The usual application of this, the “responsible persons” statute, is to employers, or their executives, who fail to remit…
2Cases cited10 opinions
- Slodov v. United StatesSupreme Court of the United States · 1978
- Louis W. Levit, Trustee of V.N. Deprizio Construction Co. v. Ingersoll Rand Financial CorporationCourt of Appeals for the Seventh Circuit · 1989
- Robert W. Monday v. United States of America, and Third-Party v. John A. Monday, Third-PartyCourt of Appeals for the Third Circuit · 1970
- Fidelity Bank, N. A. v. United States v. Fidelity Bank, N. A., on Counterclaim-AppelleeCourt of Appeals for the Tenth Circuit · 1980
- First National Bank in Palm Beach, of the Will of Frederick S. Holmes v. United States of America, J. W. Perry, Third-PartyCourt of Appeals for the First Circuit · 1979
5 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- King Ex Rel. Estate of King v. KramerCourt of Appeals for the Seventh Circuit · 2014
- Orix Credit Alliance, Inc. v. Taylor MacHine Works, Inc., and William D. MettsCourt of Appeals for the Seventh Circuit · 1997
- Albert A. Stevens v. United States of America, Cross-AppelleeCourt of Appeals for the Seventh Circuit · 1995
- National Organization for Women, Inc. v. ScheidlerCourt of Appeals for the Seventh Circuit · 2001
- Mary A. Buchanan and Gordon Buchanan, Jr. v. United States of America, Cross-AppelleeCourt of Appeals for the Seventh Circuit · 1996
9 more not listed; retrieve them via the Exa API.