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OLSEN v. U.S.

No. 91-1440.

952 F.2d 236 (1991)

Douglas A. OLSEN, Appellant, v. UNITED STATES of America, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided December 26, 1991.

Attorney(s) appearing for the Case

R. Donald Hawkinson, Minneapolis, Minn., argued, for appellant.

Paula K. Speck, argued (Shirley D. Peterson, Gary R. Allen, Kenneth L. Greene, Christine A. Grant and Jerome G. Arnold, of counsel, on the brief), Washington, D.C., for appellee.

Before LAY, Chief Judge, ARNOLD, Circuit Judge, and STUART, Senior District Judge.

STUART, Senior District Judge.

Appellant Olsen claims that the Internal Revenue Service (IRS) wrongfully imposed a 100% penalty against him under I.R.C. § 6672 (1988). He seeks a tax refund of $45,615.85. The principal issue in the case is whether Olsen, concededly a "responsible person" under § 6672, willfully failed to pay over to the IRS withheld federal employment taxes collected by his corporation, Precision Machine and Design, Inc. (Precision...

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