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NOTES 969 Tax Lawyer, Vol. 53, No. 4 NOTE SHOULD FINANCIAL DIFFICULTIES CONSTITUTE REASONABLE CAUSE FOR NONPAYMENT OF EMPLOYMENT TAXES? THE THIRD CIRCUIT’S ROBIN HOOD RESPONSE IN EAST WIND INDUSTRIES, INC. V. UNITED STATES In East Wind Industries, Inc. v. United States, the Third Circuit held that the taxpayer was entitled to an abatement of the penalties on its delinquent employmeen taxes, because the nonpayment of trust fund taxes was due to reasonable cause, rather than willful neglect.1 The...