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CORIGLIANO v. U.S.

Civ. A. No. 91-7376.

829 F.Supp. 114 (1993)

Dominick A. CORIGLIANO v. UNITED STATES of America, Defendant, Third Party Plaintiff, v. Edward M. WAVER, Third-Party Defendant.

United States District Court, E.D. Pennsylvania.

June 22, 1993.

Attorney(s) appearing for the Case

David Lyle Segal and Jeffrey H. Homel, Philadelphia, PA, for plaintiff.

Karl J. Fingerhood and Michael J. Salem, Trial Attys., Tax Div., U.S. Dept. of Justice, Washington, DC, for the U.S.

Edward M. Weaver, pro se.

MEMORANDUM

RAYMOND J. BRODERICK, District Judge.

Plaintiff Dominick A. Corigliano commenced this action against the United States of America for a refund of a sum which he paid toward a federal tax assessment that had been levied against him by the Internal Revenue Service ("IRS"). The IRS made the assessment pursuant to 26 U.S.C. § 6672, based on its determination that Mr. Corigliano was a "responsible person" who had willfully failed to see...

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