Myers v. United States, No. 18-11403 (11th Cir. 2019)Annotate this Case
26 U.S.C. 6672(a) applies with equal force when a government agency receiver tells a taxpayer not to pay trust fund taxes. The Eleventh Circuit affirmed the district court's grant of summary judgment for the Government in an action brought by plaintiff, seeking a refund of tax penalties paid under section 6672(a). The court rejected plaintiff's "my-boss-told-me-not-to-pay" argument, and held that it could not apply different substantive law because the receiver in this case was the Small Business Administration.