Court of Appeals for the Ninth Circuit March 20, 1997, 95-17089 (Henry D. Buffalow, Jr., Plaintiff-Counter-Claim-Defendant-Appellant v. United States of America, Defendant-Counter-Claimant-Appellee)

FERNANDEZ, Circuit Judge.

Henry D. Buffalow, Jr. appeals from the district court’s judgment in favor of the United States in which the court determined that he was responsible for the payment of a penalty because of the failure to pay over taxes withheld from employees’ wages by Buffalow’s, Inc. in 1989 and 1990.