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UNITED STATES v. MESSINA BUILDERS AND CONTRACTORS

No. 85-2505.

801 F.2d 1029 (1986)

UNITED STATES of America, Appellant, v. MESSINA BUILDERS AND CONTRACTORS CO., and Mike Messina, Appellees.

United States Court of Appeals, Eighth Circuit.

Decided September 23, 1986.

Attorney(s) appearing for the Case

Bruce R. Ellisen, Washington, D.C., for appellant.

Richard B. Pener, Kansas City, Mo., for appellees.

Before JOHN R. GIBSON, MAGILL, and FAIRCHILD, Circuit Judges.

MAGILL, Circuit Judge.

This appeal concerns whether the Internal Revenue Service ("IRS") must notify a third party, who provides the wages an employer pays its employees, of the employer's tax deficiency on those wages. For the reasons discussed below, we affirm the judgment of the district court1 that notice is required to a third-party provider.

I. PERTINENT STATUTES.

At the heart of this dispute are Internal Revenue...

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