Whiteside v. United States

OPINION

HORN, Judge.

BACKGROUND

Plaintiff, William Whiteside, brings this action for the refund of one-hundred (100) dollars in federal trust fund taxes, paid to the defendant, the United States, in this case the Internal Revenue Service. The defendant has counterclaimed for the unpaid portion of taxes due, in the amount of $140,063.67, assessed against plaintiff Whiteside pursuant to section 6672 of the Internal Revenue Code of 1954, 26 U.S.C. § 6672 (1988), for the allegedly unpaid trust fund taxes of General Freights, Inc. for two tax quarters ending December 31, 1983, and March 31, 1984.

FACTS