LOGAL v. U.S.

No. 98-41190.

195 F.3d 229 (1999)

Michael P. LOGAL, Plaintiff-Counter Defendant-Appellant, v. UNITED STATES of America, Defendant-Counter Claimant-Appellee.

United States Court of Appeals, Fifth Circuit.

November 22, 1999.


Attorney(s) appearing for the Case

Lawrence R. Jones, Jr. (argued), Townsend & Jones, Dallas, TX, for Logal.

Curtis C. Pett (argued), David English Carmack, U.S. Dept. of Justice, Tax Div., Washington, DC, for U.S.

Before POLITZ, DAVIS, and STEWART, Circuit Judges.


W. EUGENE DAVIS, Circuit Judge:

Michael P. Logal appeals from a district court judgment against him under 26 U.S.C. § 6672 for failure to pay the Internal Revenue Service amounts due in employee withholding taxes and penalties. Logal challenges: (i) the jury's determination that he was a "responsible person" for all three tax quarters at issue and "willful" for the second quarter of 1994, (ii) the district court's failure to instruct the jury on his reasonable...

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