Staff IT, Inc. v. United States
Court of Appeals for the Fifth Circuit
1Opinion of the Court
WIENER, Circuit Judge:
Plaintiff-Appellant Staff IT, Inc. (“S.I.”) failed to file, pay, and deposit payroll taxes during the course of three tax quarters. The Internal Revenue Service (“IRS”) initiated collection proceedings against S.I., seeking the unpaid taxes, interest on them, and penalties for S.I.’s failure timely to file, pay, and deposit such taxes. After the IRS Office of Appeals administratively sustained a proposed levy, S.I. filed a com plaint in the district court, contending that, because of financial hardship, it should be excused from paying the penalties. The district court…
2Cases cited10 opinions
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