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Spyros S. Skouras and Spyros S. Skouras, Jr., Plaintiffs-Counter-Defendants-Appellants v. United States of America, Defendant-Counter-Claimant-Appellee
Citations: 26 F.3d 13; 73 A.F.T.R.2d (RIA) 1044; 1994 U.S. App. LEXIS 13468Docket: 1718
Court: Court of Appeals for the Second Circuit; June 6, 1994; Federal Appellate Court
Spyros S. Skouras and Spyros S. Skouras, Jr. appealed a judgment from the United States District Court for the Southern District of New York, which found them liable for $786,999.51 due to their failure to remit federal income and social security trust fund taxes withheld from employee wages by Prudential Lines, Inc. (PLI) in the first quarter of 1986. At the time, Spyros S. Skouras served as CEO, while his son was one of the vice-presidents overseeing the Finance Department. The district court granted the government's motion for summary judgment, determining that the appellants willfully failed to pay the taxes under 26 U.S.C. § 6672. The appellants argued that there were genuine issues regarding their willfulness, their status as responsible corporate officers, and whether the IRS was estopped from collecting the taxes. The Court of Appeals affirmed the district court's decision, agreeing with Judge Patterson’s reasoning. It noted that while willfulness is typically a jury question, it can be resolved at the summary judgment stage if the record supports it. The court referenced precedents indicating that a directed verdict or summary judgment can be appropriate in similar cases. Ultimately, the judgment against the appellants was upheld.