· 8/21/1975
Wallace L. Sorenson v. United States
Citations
- 521 F.2d 325
- 36 A.F.T.R.2d (RIA) 5659
- 1975 U.S. App. LEXIS 13037
How courts have described this case
Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.
- concluding that “he acted with a reckless disregard for obvious risks,” sufficient to satisfy the willfulness requirement
- explaining that for every $100 Sorenson paid in wages, only $10 would be withheld, leaving employees with a claim, including interest, against the' company for $11.11
- holding that an individual was willful: “If [Sorenson] did not understand his responsibilities it is because he did not ask those who could have informed him; and if he did not ask we are inclined to believe that was because he preferred ignorance”
- wages paid to employees with knowledge that there were insufficient funds to pay both wages and taxes
- “[T]he payment of net wages in circumstances where there are no available funds in excess of net wages from which to make withholding is a willful failure to collect and pay over under § 6672.”
Source: CourtListener parenthetical corpus (CC0).
Judges: Duniway, Sneed, Plummer
Read full opinion on CourtListenerSourced from CourtListener / Free Law Project (CC0).
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