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QUATTRONE ACCOUNTANTS, INC. v. I.R.S.

No. 89-3386.

895 F.2d 921 (1990)

QUATTRONE ACCOUNTANTS, INC. and Philip P. Quattrone, Appellants, v. INTERNAL REVENUE SERVICE.

United States Court of Appeals, Third Circuit.

Decided February 12, 1990.

Attorney(s) appearing for the Case

Paul R. Yagelski, Pittsburgh, Pa., for appellants.

Gary R. Allen, Deborah Swann, Kenneth L. Greene, Appellate Section, Tax Div., Dept. of Justice, Washington, D.C., for appellee.

Before HUTCHINSON and NYGAARD, Circuit Judges, and DUBOIS, District Judge.

Submitted Pursuant to Third Circuit Rule 12(6) October 26, 1989.

OPINION OF THE COURT

NYGAARD, Circuit Judge

Debtor, Quattrone Accountants, Inc. (debtor) and Philip P. Quattrone appeal from the order of the district court affirming the bankruptcy court's determination that debtor is a responsible person who willfully failed to pay over federal employment taxes incurred by the United Dairy Farmers Cooperative Association (UDF) under 26 U.S.C. §...

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