Cook v. United States

OPINION

ALLEGRA, Judge.

This case is before the court following a trial held in Dallas, Texas. At issue is whether plaintiff is liable for a so-called “responsible officer” penalty imposed upon him *64under section 6672 of the Internal Revenue Code of 1986 (26 U.S.C.). Plaintiff paid $100 of this penalty and seeks a refund; defendant has counterclaimed for the balance of the assessment, $97,976.00, plus interest. For the reasons that follow, this court concludes that plaintiff is liable for this penalty.

I. STATEMENT OF FACTS

On June 28,1982, David F. Cook (plaintiff) and three other investors…