United States v. Lewis

FLAUM, Circuit Judge.

The district court in this case held National Homes Construction Corporation liable for unpaid withholding taxes pursuant to section 3505(a)1 of the Internal Revenue Code of 1954. Under section 3505(a), any third party who pays wages directly to the employees of an employer is liable for the taxes required to be withheld from those wages. This appeal raises the issue of whether the government’s claim against National Homes is barred either by the six-year statute of limitations contained in section 6502(a)(1)2 or by the failure to provide National Homes with notice of…