Henry D. Buffalow, Jr., Plaintiff-Counter-Claim-Defendant-Appellant v. United States of America, Defendant-Counter-Claimant-Appellee

FERNANDEZ, Circuit Judge.

Henry D. Buffalow, Jr. appeals from the district court’s judgment in favor of the United States in which the court determined that he was responsible for the payment of a penalty because of the failure to pay over taxes withheld from employees’ wages by Buffalow’s, Inc. in 1989 and 1990. He asserts that he is not responsible for the penalty because his failure to pay the taxes was not willful and because various tax payments, which were made, were improperly allocated by the Internal Revenue Service. We affirm.

BACKGROUND

Buffalow was the president and the sole…