Legal Opinion

De Alto v. United States

United States Court of Federal Claims

Decided May 13, 1998No. 96-4TPublishedCited by 8 opinions

1Opinion of the Court

OPINION

BRUGGINK, Judge.

Plaintiff Richard G. De Ato seeks to recover his 1992 personal income tax refund withheld by the United States and to abate an assessment of taxes and penalties against him. Defendant counterclaims for the unpaid balance of that assessment. The sole issue at trial was whether and to what extent plaintiff was a “responsible person” under 26 U.S.C. § 6672 (1994). The court has juris*870diction over this matter pursuant to 28 U.S.C. §§ 1346(a)(1), 1491, 1503 (1994). Trial was held in New York City on March 9-11, 1998.

BACKGROUND

The facts in this case revolve around the failure…

2Cases cited18 opinions

  1. United States v. JanisSupreme Court of the United States · 1976
  2. Slodov v. United StatesSupreme Court of the United States · 1978
  3. Waymon Leon Howard v. United StatesCourt of Appeals for the Fifth Circuit · 1983
  4. Dudley J. Godfrey, Jr., Appellant/cross-Appellee v. United States, Appellee/cross-AppellantCourt of Appeals for the Federal Circuit · 1984
  5. Richard L. Gephart v. United StatesCourt of Appeals for the Sixth Circuit · 1987

13 more not listed; retrieve them via the Exa API.

3Cited by8 opinions

  1. Jenkins v. United StatesUnited States Court of Federal Claims · 2011
  2. Salzillo v. United StatesUnited States Court of Federal Claims · 2005
  3. Noffke v. United StatesUnited States Court of Federal Claims · 2016
  4. City of Philadelphia v. GoInternet Net, Inc.Commonwealth Court of Pennsylvania · 2007
  5. De Alto v. United StatesUnited States Court of Federal Claims · 1998

3 more not listed; retrieve them via the Exa API.

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