First National Bank in Palm Beach, of the Will of Frederick S. Holmes v. United States of America, J. W. Perry, Third-Party

How courts have described this case

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

• if penalties accruing under § 6672 have not yet been assessed, government must apply taxpayer’s payments to principal amount of tax owing rather than to penalties
• “If individuals dominate a corporation, that relationship is relevant to whether they are ‘responsible persons’ within the meaning of § 6672. We are concerned with actual control and economic reality, not paper facades.”

Source: CourtListener parenthetical corpus (CC0).