Ollie B. Hadley, Plaintiff-Counterclaim-Defendant-Appellant v. United States of America, Defendant-Counterclaimant-Appellee
Court of Appeals for the Ninth Circuit
1Opinion of the Court
BOOCHEVER, Circuit Judge:
Ollie B. Hadley was assessed a penalty in the amount of $218,032 for willful failure to pay delinquent withholding taxes under 26 U.S.C. § 6672. The government filed a claim to reduce that assessment to judgment. During the course of pretrial discovery, the government served a request for admissions on Hadley. Hadley failed to respond within 30 days, and the matters were deemed admitted under Fed.R.Civ.P. 36(a). The deemed admissions amounted to a complete admission of liability for willful failure to pay the taxes under § 6672. Hadley filed a mo*1347tion to withdraw the…
2Cases cited8 opinions
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- Federal Deposit Insurance Corporation v. Richard Prusia, Federal Deposit Insurance Corporation v. Richard PrusiaCourt of Appeals for the Eighth Circuit · 1994
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