James M. O'COnnOr v. United States of America, & Third Party v. Richard Voight, Third Party

How courts have described this case

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

• indicating that ___ ________ 6672(a) liability must derive from substance, not form
• finding question of fact as to responsible person status when “passive investor” did not exercise authority in managing the company, did not dictate the financial decisions of the company, and had no authority to do so
• finding question of fact as to responsible person status when \passive investor\ did not exercise authority in managing the company, did not dictate the financial decisions of the company, and had no authority to do so
• “Most corporate officers probably do have the authority to make disbursements.... The focus must instead be on substance rather than form.”
• \To ignore [the separation of ownership and authority] would be to envelop within 'responsible person' all significant investors with titles in corporations which fail to pay their withholding taxes.\
• “To ignore [the separation of ownership and authority] would be to envelop within ‘responsible person’ all significant investors with titles in corporations which fail to pay their withholding -taxes.”

Source: CourtListener parenthetical corpus (CC0).