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U.S. v. CHILA

No. 88-3564.

871 F.2d 1015 (1989)

UNITED STATES of America, Plaintiff-Appellee, v. John A. CHILA, Defendant-Appellant.

United States Court of Appeals, Eleventh Circuit.

April 27, 1989.

Attorney(s) appearing for the Case

Lisa S. Odom, Lloyd T. Asbury, Jacksonville, Fla., for defendant-appellant.

Gary R. Allen, William S. Estabrook and Janet A. Bradley, Tax Div., Asst. Attys. Gen., Dept. of Justice, Washington, D.C., for plaintiff-appellee.

Before RONEY, Chief Judge, HILL, Circuit Judge, and TUTTLE, Senior Circuit Judge.

TUTTLE, Senior Circuit Judge:

This is an appeal from a summary judgment granted in favor of the United States in an action brought against a "responsible person" for a 100 percent penalty provided under Section 6672 of the Internal Revenue Code.1

I. STATEMENT OF THE CASE

On August 11, 1980, the Internal Revenue Service undertook to assess John A. Chila, as a responsible person of Professional Concrete Services, Inc.,...

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