Williams v. United States

ORDER

ANDEWELT, Judge.

In this tax action, the Internal Revenue Service (IRS), pursuant to Section 6672 of the Internal Revenue Code, 26 U.S.C. (the Code), assessed a penalty against plaintiff, Michael G. Williams, for failing to segregate and pay over to the IRS social security and income taxes withheld from employees of the Williams Bridge Company (WBC) during the last quarter of 1984 and the first half of 1985. Plaintiff paid a portion of this penalty and then brought the instant action seeking a refund of that payment. In response to plaintiff’s complaint, defendant filed a counterclaim…