James R. Cash v. Ellis Campbell, Jr., District Director of Internal Revenue

RIVES, Circuit Judge.

The appellant’s brief asserts:

“The sole question presented for review is whether on the evidence as presented the trial court could have properly held that appellant, ‘knowing at all times during the period involved of his obligation to-collect, truthfully account for and pay over the withholding and social security taxes, and having failed to-pay over such taxes and having preferred subsequent creditors over the United States, such failure to pay-over the taxes to the United States was without reasonable cause and. therefore willful within the meaning of § 6672.’ (R.…