Legal Opinion

Conway v. United States

Court of Appeals for the Fifth Circuit

Decided July 19, 2011No. 10-40485PublishedCited by 16 opinions

1Opinion of the Court

HAYNES, Circuit Judge:

Michael Conway (“Conway”) appeals from the district court’s summary judgment determination that, pursuant to 26 U.S.C. § 6672, he is personally liable for excise taxes that National Airlines (“National”) collected from its passengers but failed to pay over to the United States during his tenure as National’s CEO. Because we hold that the district court properly found that Conway was a “responsible person” 1 and that his failure to pay taxes was willful, as defined by this circuit’s precedents, we AFFIRM the judgment of the district court.

I. Background

Conway founded…

2Cases cited17 opinions

  1. Leslie Wayne Yohey v. James A. Collins, Director Department of Criminal Justice Institutional DivisionCourt of Appeals for the Fifth Circuit · 1993
  2. United States v. BoyleSupreme Court of the United States · 1985
  3. Begier v. Internal Revenue ServiceSupreme Court of the United States · 1990
  4. Slodov v. United StatesSupreme Court of the United States · 1978
  5. Mazo v. United StatesCourt of Appeals for the Fifth Circuit · 1979

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3Cited by16 opinions

  1. NPR Investments, L.L.C. Ex Rel. Roach v. United StatesCourt of Appeals for the Fifth Circuit · 2014
  2. Schiffmann v. United StatesCourt of Appeals for the First Circuit · 2016
  3. Jenkins v. United StatesUnited States Court of Federal Claims · 2011
  4. Roger Byrne v. United StatesCourt of Appeals for the Sixth Circuit · 2017
  5. Raymond Nakano v. United StatesCourt of Appeals for the Ninth Circuit · 2014

11 more not listed; retrieve them via the Exa API.

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