Alten v. Ellin & Tucker, Chartered

MEMORANDUM OPINION

LATCHUM, Senior District Judge.

I. INTRODUCTION

Defendants, Ellin & Tucker, Chartered (“Ellin & Tucker”) and Joel Kaye (“Kaye”), have moved for summary judgment, (Docket Item [“D.I.”] 37), against plaintiff Steven R. Alten (“Alten”), pursuant to Rule 56 of the Federal Rules of Civil Procedure. Plaintiff filed this suit to recover over $140,000.00 of tax penalties imposed upon him personally by the Internal Revenue Service, pursuant to 26 U.S.C. § 6672(a), as a “responsible person” who “willfully” failed to pay federal employee withholding taxes. Plaintiff alleges that this…