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5 canonical passages across 3 cases, quoted by 21 opinions in total. These passages cluster together because the same opinions keep quoting them side by side: they state parts of one doctrine. The anchor passage is from Mark Z. Greenberg v. United States of America Department of the Treasury Internal Revenue Service.
| # | Case | Flag | Canonical passage | Citers |
|---|---|---|---|---|
| 1 | Mark Z. Greenberg v. United States of America Department of the Treasury Internal Revenue Service Anchor | green | “it is no defense that the corporation was in financial distress and that funds were spent to keep the corporation in business with an expectation that sufficient revenue would later become available to pay the united states.” | 6 |
| 2 | Mark Z. Greenberg v. United States of America Department of the Treasury Internal Revenue Service | green | “reckless disregard includes failure to investigate or correct mismanagement after being notified that withholding taxes have not been paid.” | 6 |
| 3 | Quattrone Accountants, Inc. And Philip P. Quattrone v. Internal Revenue Service | green | “responsibility is a matter of status, duty or authority, not knowledge.” | 4 |
| 4 | Mark Z. Greenberg v. United States of America Department of the Treasury Internal Revenue Service | green | “a voluntary, conscious and intentional decision to prefer other creditors over the government” | 3 |
| 5 | Lou Brounstein v. United States | green | “under section 6672(a), willfulness is 'a voluntary, conscious and intentional decision to prefer other creditors over the government.' a responsible person acts willfully when he pays other creditors in preference to the irs knowing that taxes are due, or with reckless disregard…” | 2 |
A red or yellow flag on a member means the underlying case has negative treatment: for those, check the case page before relying on the passage.