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PLETT v. U.S.

No. 98-1752.

185 F.3d 216 (1999)

Donald PLETT, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Fourth Circuit.

Decided: July 23, 1999.

Attorney(s) appearing for the Case

ARGUED: Walter J. Rockler, Arnold & Porter, Washington, D.C., for Appellant. Charles Foster Marshall, III, Tax Division, United States Department of Justice, Washington, D.C., for Appellee. ON BRIEF: Julius M. Greisman, Katherine M. Breaks, Arnold & Porter, Washington, D.C., for Appellant. Loretta C. Argrett, Assistant Attorney General, Ann B. Durney, Helen F. Fahey, United States Attorney, Tax Division, United States Department of Justice, Washington, D.C., for Appellee.

Before NIEMEYER, WILLIAMS, and TRAXLER, Circuit Judges.

Affirmed in part, vacated in part, and remanded for further proceedings by published opinion. Judge NIEMEYER wrote the opinion, in which Judge WILLIAMS and Judge TRAXLER joined.

OPINION

NIEMEYER, Circuit Judge:

The district court entered a $50,000 judgment in favor of the United States (Internal Revenue Service) against Donald Plett representing the 100% penalty imposed by 26 U.S.C. § 6672, plus interest, for Plett's failure to remit payroll...

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