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KINNIE v. U.S.

No. 92-1690.

994 F.2d 279 (1993)

William A. KINNIE, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided May 24, 1993.

Attorney(s) appearing for the Case

George M. Malis (argued & briefed), Timmis & Inman, Detroit, MI, for plaintiff-appellant.

Mark D. Lansing, Trial Atty., Gary R. Allen, Acting Chief (briefed), Richard Farber, Samuel R. Lyons (argued), U.S. Dept. of Justice, Appellate Section Tax Div., Washington, DC, for defendant-appellee.

Before: KENNEDY, MILBURN, and NORRIS, Circuit Judges.

MILBURN, Circuit Judge.

Plaintiff William A. Kinnie appeals the district court's grant of summary judgment in favor of defendant United States of America in Kinnie's action seeking recovery of penalties assessed and collected by the Internal Revenue Service ("IRS") under 26 U.S.C. § 6672. On appeal, the issues are (1) whether Kinnie was a responsible person who willfully failed to pay to the United States income and social security taxes withheld from the wages...

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