Legal Opinion
Salzillo v. United States
United States Court of Federal Claims
Decided April 4, 2005No. 02-1393TPublishedCited by 8 opinions
1Opinion of the Court
OPINION
ALLEGRA, Judge.
“Law, being a practical thing, must found itself on actual forces____If it should do otherwise, it would become a matter for pedagogues, wholly devoid of reality.”1
This tax refund case is before the court following trial in San Antonio, Texas. At issue is whether plaintiff is liable for a so-called “responsible officer” penalty imposed by section 6672(a) of the Internal Revenue Code of 1986 (26 U.S.C.). Plaintiff paid $12,667.00 of this penalty and seeks a refund; defendant has counterclaimed for the balance of the assessment, $541,097.07, plus interest. For the reasons…
2Cases cited37 opinions
- Slodov v. United StatesSupreme Court of the United States · 1978
- United States v. Mary Rem, Syma Lichter, and Nathan Hanfling, as Executors of the Estate of Henry Rem, Gerard RemCourt of Appeals for the Second Circuit · 1994
- United States v. SoteloSupreme Court of the United States · 1978
- Waymon Leon Howard v. United StatesCourt of Appeals for the Fifth Circuit · 1983
- Joseph F. Purcell, Plaintiff-Counter-Claim-Defendant-Appellant v. United States of America, Defendant-Counter-Claimant-AppelleeCourt of Appeals for the Ninth Circuit · 1993
32 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Jenkins v. United StatesUnited States Court of Federal Claims · 2011
- Beard v. United StatesUnited States Court of Federal Claims · 2011
- Smith v. United StatesCourt of Appeals for the Tenth Circuit · 2009
- Noffke v. United StatesUnited States Court of Federal Claims · 2016
- Waterhouse v. United StatesUnited States Court of Federal Claims · 2015
3 more not listed; retrieve them via the Exa API.