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UNITED STATES v. POMPONIO

No. 80-1080.

635 F.2d 293 (1980)

UNITED STATES of America, Appellant, v. Louis POMPONIO, Jr., Mary Lou Pomponio, Peter Pomponio, Carolyn Pomponio, Paul Pomponio, Appellees, and Judith BROCKSMITH (formerly Judith Pomponio), Defendant, v. Charles J. PILUSO, Third Party Defendant.

United States Court of Appeals, Fourth Circuit.

Decided November 26, 1980.

Attorney(s) appearing for the Case

Wynette J. Hewett, Tax Div., Dept. of Justice, Washington, D.C. (Justin W. Williams, U. S. Atty., M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews, Gary R. Allen, Tax Div., Dept. of Justice, Washington, D.C., on brief), for appellant.

Walter T. Charlton, Washington, D.C. (Charlton & Tupling, Lawrence D. Huntsman, Washington, D.C., on brief), for appellees.

Before HAYNSWORTH, Chief Judge, FIELD, Senior Circuit Judge, and PHILLIPS, Circuit Judge.

FIELD, Senior Circuit Judge:

The United States filed actions against three brothers, Peter, Paul, and Louis Pomponio, respectively, and their wives,1 seeking judgments stemming from (1) certain income tax liabilities, (2) assessments made against them under section 6672 of the Internal Revenue Code of 1954, 26 U.S.C. § 6672,2 with respect to withholding taxes on wages owed by various corporations owned...

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