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  5. 794 F.2d 1248 (1986)
 

MATTER OF AVILDSEN TOOLS & MACHINE, INC.

Nos. 84-2739, 85-1049.

794 F.2d 1248 (1986)

In the Matter of AVILDSEN TOOLS & MACHINE, INC., A Delaware Corporation, Debtor-Appellant. Edward B. AVILDSEN and Morton Balon, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided July 7, 1986.

Attorney(s) appearing for the Case

David Leibowitz, Schwartz Cooper Kolb & Gaynor, Chicago, Ill., for debtor-appellant.

Wynette J. Hewett, Tax Div., Dept. of Justice, Washington, D.C., for defendant-appellee.

Before COFFEY and RIPPLE, Circuit Judges, and CAMPBELL, Senior District Judge.

COFFEY, Circuit Judge.

The appellants-taxpayers, Avildsen Tools & Machine, Inc., Edward Avildsen and Morton Balon, two of Avildsen Tools' officers, appeal the district court's order reversing a bankruptcy court decision and imposing a 100 percent assessment penalty, pursuant to 26 U.S.C. § 6672, for failure to pay corporate withholding taxes in violation of 26 U.S.C. § 7501. We affirm.

I

The first case in this appeal, No. 84-2739, arose...

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