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LUBETZKY v. U.S.

No. 01-2357.

393 F.3d 76 (2004)

Itamar LUBETZKY, Plaintiff, Appellant, v. UNITED STATES of America, Defendant, Appellee.

United States Court of Appeals, First Circuit.

Decided December 29, 2004.

Attorney(s) appearing for the Case

Timothy J. Burke for appellant.

Gretchen M. Wolfinger, Tax Division, Department of Justice, with whom Eileen J. O'Connor, Assistant Attorney General, Michael J. Sullivan, United States Attorney, and Bruce R. Ellisen, Tax Division, Department of Justice, were on brief for appellee.

Before BOUDIN, Chief Judge, LYNCH, Circuit Judge, and SCHWARZER, Senior District Judge.

BOUDIN, Chief Judge.

Itamar Lubetzky appeals from a jury verdict holding him personally liable for the federal withholding taxes of MediaForum, Inc. for the six quarters of July 1, 1996 through December 31, 1997. Lubetzky's central challenge is to the sufficiency of the evidence, but his appeal also invites attention to the murky standards for imposing liability. We begin with a brief summary of the statute, the background events and the legal proceedings that followed...

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