Douglas A. Olsen v. United States

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• noting that liability for federal employment tax withholdings coincides with collection of funds and not the date the employer is required to pay them over to the government
• noting that an individual may be a “responsible person” without having exclusive control over finances
• recognizing the circuit courts of appeals are divided as to whether a reasonable cause defense may militate against a finding of willfulness, but noting “[t]his court has held that reasonable cause is no part of the definition of willfulness”
• party did not show affirmative act where IRS agents erroneously told him IRS held superior lien on his property
• “In order for Olsen to prevail on estoppel he must prove that the IRS agents in addition to the ordinary elements of estoppel that the agents were guilty of affirmative misconduct.”
• “Evidence that the 6 In his reply brief, Musal argues that we had previously addressed and rejected this principle in United States v. Bisbee, 245 F.3d 1001 (8th Cir. 2001

Source: CourtListener parenthetical corpus (CC0).