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RABA v. U.S.

No. 91-5782.

977 F.2d 941 (1992)

Lawrence RABA, et al., Plaintiffs, v. UNITED STATES of America, Counter-Claimant-Appellee, v. Lawrence RABA, et al., Counter-Defendants, Raymond Mirelez, Counter-Defendant-Appellant.

United States Court of Appeals, Fifth Circuit.

November 23, 1992.

Attorney(s) appearing for the Case

Edward Daneri, Antonio, Tex., for Mirelez.

Jordan Glickstein, Atty., Gary R. Allen, Chief, David I. Pincus, Appellate Sec., Tax Div., Dept. of Justice, Washington, D.C., for appellee.

Before GOLDBERG, SMITH, and EMILIO M. GARZA, Circuit Judges.

JERRY E. SMITH, Circuit Judge:

Raymond Mirelez appeals a judgment finding him liable for $122,281.45, less credits for payments, plus interest, pursuant to 26 U.S.C. § 6621(a)(2). The district court determined Mirelez was a responsible person, required to collect and pay over payroll taxes, who willfully failed to do so under id. § 6672. Finding no error, we affirm.

I.

Mirelez started to...

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