Legal Opinion
Ralph H. Brown v. United States of America, Defendant-Third Party v. Don R. Sibley, Third Party
Court of Appeals for the Third Circuit
Decided March 23, 1979No. 76-2381PublishedCited by 77 opinions
1Opinion of the Court
ALVIN B. RUBIN, Circuit Judge:
Section 6672 of the Internal Revenue Code of 1954, 26 U.S.C. § 6672, provides that responsible persons who “willfully” fail to ensure that their corporation pays federal withholding taxes are liable for a penalty in the amount not paid. This case involves questions concerning the liability of two officers, Ralph H. Brown and Don R. Sibley, of Sibwin, Inc. for penalties under § 6672 because of Sibwin’s failure to pay withholding taxes for the first quarter of 1972. 1 Each asserts that the other was the only person responsible for seeing that the liability was…
2Cases cited14 opinions
- Slodov v. United StatesSupreme Court of the United States · 1978
- Robert W. Monday v. United States of America, and Third-Party v. John A. Monday, Third-PartyCourt of Appeals for the Third Circuit · 1970
- Mazo v. United StatesCourt of Appeals for the Fifth Circuit · 1979
- J. A. Newsome, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1970
- George D. Hartman, Jr. v. United StatesCourt of Appeals for the Eighth Circuit · 1976
9 more not listed; retrieve them via the Exa API.
3Cited by77 opinions
- Mazo v. United StatesCourt of Appeals for the Fifth Circuit · 1979
- Waymon Leon Howard v. United StatesCourt of Appeals for the Fifth Circuit · 1983
- Gail McClendon v. United StatesCourt of Appeals for the Fifth Circuit · 2018
- Richard D. Barnett v. Internal Revenue ServiceCourt of Appeals for the Fifth Circuit · 1993
- Dan O. Davis, Plaintiff-Counter-Claim-Defendant-Appellant v. United States of America, Defendant-Counter-Claimant-AppelleeCourt of Appeals for the Ninth Circuit · 1992
72 more not listed; retrieve them via the Exa API.