Legal Opinion

James M. O'COnnOr v. United States of America, & Third Party v. Richard Voight, Third Party

Court of Appeals for the Third Circuit

Decided March 2, 1992No. 91-2623PublishedCited by 63 opinions

1Opinion of the Court

OPINION

HAMILTON, Circuit Judge:

James M. O’Connor appeals the order of the district court granting summary judgment in favor of the Internal Revenue Service (IRS) on his claim for refund of a penalty imposed on him under 26 U.S.C. § 6672. The district court granted summary judgment based on the conclusion that O’Connor was a responsible person under the statute who willfully failed to pay withholding taxes of a corporation in which he was a part owner and officer. This appeal presents the issues of whether or not O’Connor was a responsible person under the statute, and if he was, whether or…

2Cases cited21 opinions

  1. Charbonnages De France v. Frank B. Smith, Juanita Smith, Frank Smith, Jr., Smith Brothers Construction Company and Continental Coal Sales CorporationCourt of Appeals for the Fourth Circuit · 1979
  2. Robert W. Monday v. United States of America, and Third-Party v. John A. Monday, Third-PartyCourt of Appeals for the Third Circuit · 1970
  3. Mazo v. United StatesCourt of Appeals for the Fifth Circuit · 1979
  4. Roland J. Kalb v. United States of America, and Third-Party v.jerome L. Herold, Third-PartyCourt of Appeals for the Second Circuit · 1974
  5. Dudley J. Godfrey, Jr., Appellant/cross-Appellee v. United States, Appellee/cross-AppellantCourt of Appeals for the Federal Circuit · 1984

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

3Cited by63 opinions

  1. Joseph F. Purcell, Plaintiff-Counter-Claim-Defendant-Appellant v. United States of America, Defendant-Counter-Claimant-AppelleeCourt of Appeals for the Ninth Circuit · 1993
  2. Richard D. Barnett v. Internal Revenue ServiceCourt of Appeals for the Fifth Circuit · 1993
  3. United States v. North CarolinaCourt of Appeals for the Fourth Circuit · 1999
  4. United States v. McCombsCourt of Appeals for the Second Circuit · 1994
  5. UNITED STATES v. McCOMBSCourt of Appeals for the Second Circuit · 1994

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

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