Legal Opinion
United States v. Dixieline Financial, Inc.
Court of Appeals for the Ninth Circuit
Decided April 11, 1979No. 76-3155PublishedCited by 19 opinions
1Opinion of the Court
MERRILL, Circuit Judge.
Section 3505(b) of the Internal Revenue Code of 1954 (the Code), 26 U.S.C. § 3505(b), 1 imposes liability on one who supplies funds to an employer to enable him to meet a payroll, knowing that the employer does not intend to, or will be unable to pay the taxes required to be withheld and paid to the government. The liability imposed is equal to the amount of tax due and unpaid. The Code, § 6501(a), requires that “the amount of any tax imposed by this title shall be assessed within 3 [three] years after the return was filed * * * and no proceeding in court without…
2Cases cited4 opinions
- Edward J. Bloom v. United StatesCourt of Appeals for the Ninth Circuit · 1960
- Cohen v. GrossCourt of Appeals for the Third Circuit · 1963
- Charles R. Rambo v. United States of America and District Director of Internal Revenue for the District of KentuckyCourt of Appeals for the Sixth Circuit · 1974
- United States v. WalkerDistrict Court, W.D. South Carolina · 1963
3Cited by19 opinions
- United States v. First National Bank of CircleCourt of Appeals for the First Circuit · 1981
- In Re James and Dianne Ripley, Debtors. United States of America v. James and Dianne RipleyCourt of Appeals for the Fifth Circuit · 1991
- United States v. Jersey Shore State BankCourt of Appeals for the Third Circuit · 1986
- United States of America, Cross-Appellee v. Associates Commercial Corporation, Cross-AppellantCourt of Appeals for the Seventh Circuit · 1983
- United States v. KlimekDistrict Court, E.D. Pennsylvania · 1997
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