United States v. Mary Rem, Syma Lichter, and Nathan Hanfling, as Executors of the Estate of Henry Rem, Gerard Rem

KEARSE, Circuit Judge:

Defendant Gerard Rem (“Rem” or “Gerard”) appeals from a judgment of the United States District Court for the Southern District of New York, Louis J. Freeh, Judge, awarding plaintiff United States $1,875,-179.41 against him, comprising $550,000.08 in withholding taxes owed by a corporation of which he was an officer, plus interest of $1,325,179.41. The district court granted summary judgment against Rem on the ground that he was a responsible officer of the taxpayer corporation within the meaning *637of § 6672 of the Internal Revenue Code, 26 U.S.C. § 6672 (1988). On appeal,…