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U.S. v. JONES

Nos. 92-15718, 92-16639.

33 F.3d 1137 (1994)

UNITED STATES of America, Plaintiff-Appellee, v. Robert Alan JONES, Defendant-Appellant. UNITED STATES of America, Plaintiff-Appellee, v. Renate SCHIFF, Executrix of the Estate of Marvin James Schiff, Defendant-Appellant.

United States Court of Appeals, Ninth Circuit.

Decided August 29, 1994.

Attorney(s) appearing for the Case

Jon R. Vaught, Oakland, CA, for defendant-appellant Jones.

Mark Gibbons, Oshins, Gibbons, Berkley, Segal, Berman & Wolfson, Las Vegas, NV, for defendant-appellant Schiff.

Gary R. Allen, Charles E. Brookhart, Jordan L. Glickstein, Tax Div., U.S. Dept. of Justice, Washington, DC, for plaintiff-appellee.

Before: HUG, FARRIS, and BRUNETTI, Circuit Judges.

BRUNETTI, Circuit Judge:

After a bench trial, the presiding magistrate judge found that the defendants in this case were liable under Internal Revenue Code ("IRC") § 6672 as responsible persons who willfully failed to collect, truthfully account for and pay over to the United States payroll taxes. We have jurisdiction under 28 U.S.C. § 1291. Because we hold that the factual finding that the defendants are "responsible persons" under § 6672 is clearly...

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