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SCOTT v. U.S.

No. 14-14649.

825 F.3d 1275 (2016)

Ashley SCOTT, Plaintiff-Counter Defendant-Appellant, v. UNITED STATES of America, Treasury, Department, Internal Revenue Service, Defendant-Third Party Plaintiff-Counter Claimant-Appellee.

United States Court of Appeals, Eleventh Circuit.

June 14, 2016.

Attorney(s) appearing for the Case

Keith H. Johnson , Adam Louis Heiden , Michael P. Tyson , Johnson & Johnson, PA, Jacksonville, FL, for Plaintiff-Appellant.

Janet Arlene Bradley , Marion E.M. Erickson , Jonathan S. Cohen , Philip Doyle , Pascale Guerrier , U.S. Department of Justice, Chief Appellate Section Tax Division, Washington, DC, Arthur Lee Bentley, III , U.S. Attorney's Office, Tampa, FL, for Defendant-Appellee.

Before TJOFLAT, ROSENBAUM, and ANDERSON, Circuit Judges.

This case presents the issue of whether Ashley Scott ("Scott") is a "responsible person" under 26 U.S.C. § 6672.1 A responsible person is required to pay over to the Internal Revenue Service trust fund taxes — i.e., taxes withheld by a business from employees' wages. The district...

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