Legal Opinion
Fred J. Hewitt v. United States
Court of Appeals for the Fifth Circuit
Decided June 1, 1967No. 23485_1PublishedCited by 58 opinions
1Opinion of the Court
DYER, Circuit Judge:
Pursuant to § 6672 of the Internal Revenue Code of 1954 1 *a 100% penalty was assessed against taxpayer Hewitt for his willful failure to collect and pay over the federal income and Social Security taxes withheld from employees of Hewitt and Watts, Inc., for the first quarter of 1958. Taxpayer paid the assessment, filed a claim for refund which was denied, and filed suit. At the close of all of the evidence the District Court granted a directed verdict for the government. Taxpayer claims that this was error because there were fact issues as to whether the taxpayer was a…
2Cases cited10 opinions
- Pennsylvania Railroad v. ChamberlainSupreme Court of the United States · 1933
- Edward J. Bloom v. United StatesCourt of Appeals for the Ninth Circuit · 1960
- National Bank of the Commonwealth v. Mechanics' National BankSupreme Court of the United States · 1877
- American Fidelity & Casualty Company v. Mrs. Claire DrexlerCourt of Appeals for the Fifth Circuit · 1955
- Hal C. Frazier v. United StatesCourt of Appeals for the Fifth Circuit · 1962
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3Cited by58 opinions
- Robert W. Monday v. United States of America, and Third-Party v. John A. Monday, Third-PartyCourt of Appeals for the Third Circuit · 1970
- Mazo v. United StatesCourt of Appeals for the Fifth Circuit · 1979
- J. A. Newsome, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1970
- Richard D. Barnett v. Internal Revenue ServiceCourt of Appeals for the Fifth Circuit · 1993
- Harold E. Harrington v. United StatesCourt of Appeals for the First Circuit · 1974
53 more not listed; retrieve them via the Exa API.