Court of Appeals for the Ninth Circuit December 12, 2001, No. 99-35781; D.C. No. CV-98-00620-BJR (Loew v. United States)

MEMORANDUM1

Edward J. Loew seeks a refund of $40,750 paid to the Internal Revenue Service in partial satisfaction of a trust fund recovery penalty assessed against him personally under § 6672 of the Internal Revenue Code. 26 U.S.C. § 6672. His company had failed to pay over taxes withheld from employees that are required to be held in trust for the government.