WRIGHT v. UNITED STATES

No. 86-1540.

809 F.2d 425 (1987)

Stephen R. WRIGHT, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided January 14, 1987.


Attorney(s) appearing for the Case

James O. Beavers, Hershey, Bliss, Beavers & Periard, Taylorville, Ill., for plaintiff-appellant.

Deborah Swann Mbye, Tax Div., Dept. of Justice, Washington, D.C., for defendant-appellee.

Before POSNER and COFFEY, Circuit Judges, and PELL, Senior Circuit Judge.


POSNER, Circuit Judge.

Stephen Wright appeals from a judgment of the district court, made after a two-day bench trial, upholding a $61,000 assessment against him for willful failure to pay withholding taxes. 26 U.S.C. § 6672. (He had paid part of it, then sued for a refund, which is why the case comes to us from a district court rather than the Tax Court.) The only question is whether the finding of willfulness, made by the district court in an oral opinion,...

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