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U.S. I.R.S. v. CHARLTON

No. 92-3060.

2 F.3d 237 (1993)

UNITED STATES INTERNAL REVENUE SERVICE, Plaintiff-Appellee, v. Earl A. CHARLTON, Defendant-Appellant.

United States Court of Appeals, Seventh Circuit.

Decided August 17, 1993.

Rehearing and Suggestion for Rehearing Denied September 20, 1993.

Attorney(s) appearing for the Case

John E. Fryatt, U.S. Atty., Office of the U.S. Atty., Milwaukee, WI, Gary R. Allen, Charles E. Brookhart, Billie L. Crowe (argued), Dept. of Justice, Tax Div., Appellate Section, Washington, DC, for plaintiff-appellee.

Joseph J. Welcenbach (argued), Margaret A. Watt, Welcenbach & Widmann, Milwaukee, WI, for defendant-appellant.

Before EASTERBROOK and KANNE, Circuit Judges, and ENGEL, Senior Circuit Judge.

Rehearing and Suggestion for Rehearing En Banc Denied September 20, 1993.

ENGEL, Senior Circuit Judge.

Taxpayer Earl Charlton appeals the district court's order affirming the bankruptcy court's decision holding him personally liable under section 6672 of the Internal Revenue Code for the unpaid employment taxes of five Wisconsin restaurants. This appeal requires us to determine whether the evidence was sufficient to establish that Charlton was a "responsible...

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