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GORDON v. COMMISSIONER

Docket No. 8873-79.

39 T.C.M. 769 (1979)

T.C. Memo. 1979-511

Lloyd Gordon v. Commissioner.

United States Tax Court.

Filed December 26, 1979.

Attorney(s) appearing for the Case

Roderick F. Mollison, 134 North La Salle St., Chicago, Ill. for the petitioner. Allan E. Lang, for the respondent.

Memorandum Opinion

DAWSON, Judge:

On March 26, 1979, respondent made a 100 percent penalty assessment of $23,152.77 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 and FICA taxes collected by the Alloyd Food Service Management & Investments, Inc. for various quarterly taxable periods in 1975 and 1976. A notice and demand for payment...

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