United States v. Norwood J. Patterson, (Two Cases)

GOODWIN, Circuit Judge:

Norwood J. Patterson was convicted by a jury on nine counts of violating Section 7512(b) of the Internal Revenue Code; i.e., of collecting taxes from the employees of Sierra Broadcasting, Inc., and failing to deposit them in trust within two banking days of the dates those sums were collected.

In a consolidated action, Patterson was also convicted of seven counts involving the collection of taxes from employees of Radio Station KBIF, Inc. He appeals both judgments.

Patterson and his wife owned all the stock of Sierra, and of Pattco, Inc., which owns KBIF. Patterson was…