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WOOD v. UNITED STATES

No. 86-1041.

808 F.2d 411 (1987)

L. Ray WOOD, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Fifth Circuit.

January 23, 1987.

Attorney(s) appearing for the Case

O. Jan Tyler, Dallas, Tex., for plaintiff-appellant.

Matthew J. Anderton, Roger M. Olsen, Acting Asst. Atty. Gen., Michael L. Paup, Chief Appellate Section, Richard Farber, U.S. Dept. of Justice, Tax Div., Washington, D.C., for defendant-appellee.

Before CLARK, Chief Judge, WISDOM, and HIGGINBOTHAM, Circuit Judges.

CLARK, Chief Judge:

The Internal Revenue Service assessed L. Ray Wood with $39,355.38 in unpaid withholding tax liabilities of Red Ant Products, Inc. for the second, third, and fourth quarters of 1979 and the first quarter of 1980. The IRS alleged that, as to Red Ant, Wood was a "responsible person" who willfully failed to pay the taxes, and thus was liable under 26 U.S.C. § 6672. Wood paid $6806.17 toward satisfaction...

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