Dallin v. United States

OPINION

HORN, Judge.

This case originally was captioned Donald Young v. United States. After Mr. Young died, proceedings in this case were stayed until probate was initiated, an executrix of the estate was appointed, and counsel was employed to continue representing the estate. Michelle Dallin was ultimately appointed as the executrix of Mr. Young’s estate and Mr. Janow was hired to continue his representation in the case. Therefore, the case is proceeding under the above caption.

This case arises from a penalty assessed by the IRS against Donald Young, as a responsible officer of Southern…