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United States of America v. Raymond G. Novelli

RESPONSE

12 Cited authorities

  1. Begier v. Internal Revenue Service

    496 U.S. 53 (1990)   Cited 813 times   7 Legal Analyses
    Holding that the segregation of funds was not a prerequisite to the establishment of a statutory trust under the Internal Revenue Code

  2. Volkswagenwerk Aktiengesellschaft v. Schlunk

    486 U.S. 694 (1988)   Cited 861 times   10 Legal Analyses
    Holding that a state law permitting a foreign corporation to be served domestically through its U.S. subsidiary did not implicate the Hague Service Convention

  3. Slodov v. United States

    436 U.S. 238 (1978)   Cited 566 times   1 Legal Analyses
    Holding that new management is not liable under § 6672 for trust fund delinquencies in existence at the time the new management took control

  4. Brockmeyer v. May

    383 F.3d 798 (9th Cir. 2004)   Cited 586 times   5 Legal Analyses
    Holding that the Convention allows service by mail

  5. Lucas v. Natoli

    936 F.2d 432 (9th Cir. 1991)   Cited 67 times
    Holding that there is no time limit for foreign service under the unambiguous language of FRCP 4(m)

  6. Rule 4 - Summons

    Fed. R. Civ. P. 4   Cited 68,886 times   122 Legal Analyses
    Holding that if defendant is not served within 90 days after the complaint is filed, the court—on a motion, or on its own following notice to the plaintiff—must dismiss the action without prejudice against that defendant or order that service be made by a certain time

  7. Section 6672 - Failure to collect and pay over tax, or attempt to evade or defeat tax

    26 U.S.C. § 6672   Cited 2,064 times   20 Legal Analyses
    Allowing the IRS to recover penalties from "[a]ny person required to collect, truthfully account for, and pay over" withholding taxes who "willfully" fails to do so

  8. Section 7501 - Liability for taxes withheld or collected

    26 U.S.C. § 7501   Cited 625 times   4 Legal Analyses
    Providing that revenue taxes collected by intermediaries constitute a special fund in trust for the United States

  9. Section 3102 - Deduction of tax from wages

    26 U.S.C. § 3102   Cited 613 times   8 Legal Analyses
    Relating to deduction of FICA taxes

  10. Section 3402 - Income tax collected at source

    26 U.S.C. § 3402   Cited 554 times   28 Legal Analyses
    Describing withholding requirements

  11. Section 3111 - Rate of tax

    26 U.S.C. § 3111   Cited 229 times   12 Legal Analyses
    Setting Social Security tax rates for "wages paid during" particular calendar years

  12. Section 3403 - Liability for tax

    26 U.S.C. § 3403   Cited 195 times   4 Legal Analyses
    Imposing tax under substantially similar terms as the Revenue Act of 1932