A penalty was imposed on petitioner personally pursuant to subdivision (g) of section 685 of the Tax Law for willful failure to collect and pay withholding taxes. Petitioner was president of Thomas J. Wolfstich, Inc. (Wolfstich) which had failed to pay amounts withheld from its employees as withholding taxes during the years of 1970, 1971 and 1972. Petitioner contends that (1) the imposition of a penalty against him personally is barred by the applicable Statute of Limitations...
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