James N. Bowen v. United States of America, Betty G. Bowen 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.

• finding that a taxpayer acted willfully despite the taxpayer’s good faith belief that it would be able to obtain a loan to pay over the tax liabilities
• although the Fifth Circuit has recognized conceptually that a reasonable cause may negate a finding of willfulness, \no taxpayer has yet carried that pail up the hill.\
• president and vice-president with signing authority over bank accounts held responsible persons
• “We have not accepted the mere reasonable expectation of sufficient funds at a later date as a defense to a charge of willful failure to comply with the commands of § 6672.”

Source: CourtListener parenthetical corpus (CC0).