Abel v. United States (In Re Abel)

OPINION

DIANE WEISS SIGMUND, Bankruptcy Judge:

The Debtor initiated this adversary proceeding on December 17, 1992 by fifing a Petition to Determine Tax Liability Pursuant to 11 U.S.C. § 505(a), and Objection to Claim (the “Petition”). The Court must initially decide whether the Debtor was a “responsible person” within the meaning of Internal Revenue Code (“IRC”) § 6672 during the time period in question. If this Court finds that the Debtor was a responsible person, we must then decide whether the Debtor’s failure to remit trust fund taxes during the period in question was willful. If this…