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MORGAN v. U.S.

No. 90-1442.

937 F.2d 281 (1991)

Tommy D. MORGAN, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Fifth Circuit.

Rehearing Denied September 3, 1991.

Attorney(s) appearing for the Case

Merle R. Flagg, Dallas, Tex., for plaintiff-appellant.

Elizabeth K. Wickstrom, Ann B. Durney, Gary R. Allen, Chief, Appellant Sec. Tax Div. Dept. Justice, Washington, D.C., for defendant-appellee.

Before GOLDBERG, HIGGINBOTHAM, and JONES, Circuit Judges.

PER CURIAM:

For the reasons articulated in the district court's memorandum opinion and order, Morgan v. United States, 90-1 U.S.Tax Cas. (CCH) ¶ 50,106, Unempl.Ins.Rep. (CCH) ¶ 15407A (N.D.Tex. January 25, 1990) (available on WESTLAW, 1990 WL 39106) (reprinted as Appendix), we affirm the district court's ruling that Morgan was a responsible person and acted willfully within the meaning of 26 U.S.C. § 6672(a).

Morgan's liability established...

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