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WILT v. COMMISSIONER

Docket No. 5364-73.

60 T.C. 977 (1973)

THORNTON D. WILT, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 25, 1973.

Attorney(s) appearing for the Case

Donn E. Garvey, for the petitioner.

Eli H. Schmukler and Howard L. Williams, for the respondent.

OPINION

DAWSON, Judge:

On June 18, 1973, respondent made a 100-percent penalty assessment of $110,116.57 against the petitioner pursuant to sections 6671 and 6672, I.R.C. 1954,1 as being the person responsible for the failure to pay over withholding taxes collected by the Tangier Corp. for the taxable periods ended September 30, 1969, December 31, 1969, and March 31, 1970. A notice and demand for payment (Form 17) was...

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