(DOWNLOAD) "Kennedy v. United States" by United States Court of Appeals for the Seventh Circuit # Book PDF Kindle ePub Free
eBook details
- Title: Kennedy v. United States
- Author : United States Court of Appeals for the Seventh Circuit
- Release Date : January 08, 1992
- Genre: Law,Books,Professional & Technical,
- Pages : * pages
- Size : 64 KB
Description
WOOD, JR., Circuit Judge. The Internal Revenue Service assessed a 100-percent penalty against Harold C. Gatewood and John T. Kennedy as responsible persons of a corporation that failed to pay over federal withholding taxes from employee wages. As a result of a miscalculation, an Internal Revenue Service agent represented to Gatewood's attorney that Gatewood and Kennedy owed a lesser amount of taxes than the government now demands. Gatewood and Kennedy paid the lesser amount, but they refused to pay the total amount of the corrected assessment to the IRS. The government pursued its claim against Gatewood and Kennedy in federal district court after Kennedy brought a refund suit requesting the return of approximately $5,000 withheld from his 1988 tax return by the IRS. The district court granted a summary judgment motion in the government's favor for the full amount of the corrected 100-percent assessment. Kennedy then entered into a settlement agreement with the Internal Revenue Service, but Gatewood appeals the assessment imposed against him. Gatewood maintains that the doctrine of equitable estoppel prevents the government from collecting any more money from him. We affirm the judgment of the district court. BACKGROUND FACTS