Schiffmann v. United States
Court of Appeals for the First Circuit
1Opinion of the Court
SELYA, Circuit Judge.
The obligation of a corporate employer to pay payroll taxes is familiar. The Internal Revenue Code requires employers to withhold federal income taxes from employees’ wages and to hold such taxes in trust for the United States. See 26 U.S.C. §§ 3102, 3402, 7501. As a result, such taxes are often referred to as trust fund taxes. See id. § 7501. If they are not paid to the government when and as required, the Internal Revenue Service (IRS) may look past the corporate form and hold officers of the corporation personally liable under certain circumstances. See id. § 6672(a).
Th…
2Cases cited22 opinions
- Roland J. Kalb v. United States of America, and Third-Party v.jerome L. Herold, Third-PartyCourt of Appeals for the Second Circuit · 1974
- Dudley J. Godfrey, Jr., Appellant/cross-Appellee v. United States, Appellee/cross-AppellantCourt of Appeals for the Federal Circuit · 1984
- Gomez v. Stop & Shop Supermarket Co.Court of Appeals for the First Circuit · 2012
- Richard D. Barnett v. Internal Revenue ServiceCourt of Appeals for the Fifth Circuit · 1993
- Arnold Hochstein, Counterclaim v. United States of America, CounterclaimCourt of Appeals for the Second Circuit · 1990
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