Legal Opinion
Milton R. Psaty, and Martin M. Psaty v. United States
Court of Appeals for the Third Circuit
Decided April 20, 1971No. 18750PublishedCited by 140 opinions
1Opinion of the Court
OPINION OF THE COURT
ROSENN, Circuit Judge.
The primary issues raised on this appeal arise out of the instructions by the trial court in a civil proceeding as to the burden of proof on an officer of a corporation who resists the collection of penalties for willfully failing to pay over income and social security taxes withheld from corporate employees.
The Commissioner of Internal Revenue assessed 100% penalties pursuant to Section 6672 of the Internal Revenue Code of 1954, 1 against the appellant and his brother, Martin, 2 as the responsible officers of S. F. Berkeley, Inc. (Berkeley) for…
2Cases cited17 opinions
- Flora v. United StatesSupreme Court of the United States · 1960
- New York Life Insurance v. GamerSupreme Court of the United States · 1938
- United States v. Joseph G. LeaseCourt of Appeals for the Second Circuit · 1965
- Speck v. SarverCalifornia Supreme Court · 1942
- United Aniline Company v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1963
12 more not listed; retrieve them via the Exa API.
3Cited by140 opinions
- United States v. JanisSupreme Court of the United States · 1976
- Branson v. Department of RevenueIllinois Supreme Court · 1995
- United States v. Fior D'Italia, Inc.Supreme Court of the United States · 2002
- Phillip N. Lockhart, Charles B. Wilson, James Lowery, James P. Durham and Thomas Bradley v. Westinghouse Credit CorporationCourt of Appeals for the Third Circuit · 1989
- John J. Demarines and Doris A. Demarines, Husband and Wife v. Klm Royal Dutch AirlinesCourt of Appeals for the Third Circuit · 1978
135 more not listed; retrieve them via the Exa API.