United States v. Roman A. Dimeo

65 F.3d 176 76 A.F.T.R.2d 95 -6401 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. UNITED STATES of America, Plaintiff-Appellee, v. Roman A. DiMEO, Defendant-Appellant. No. 91-55660. United States Court of Appeals, Ninth Circuit. Submitted Aug. 16, 1995. * Decided Aug. 23, 1995. Before: ALARCON, FERNANDEZ, and RYMER, Circuit Judges. 1 MEMORANDUM ** 2 Roman A. DiMeo appeals pro se the district court's judgment for the United States after a bench trial in the United States's action seeking to reduce to judgment a 100% penalty assessment against DiMeo for willful failure to collect, truthfully account for, and pay over federal withholding and social security taxes for the employees of PurAire Products, Inc. (the "Company") for the last three quarters of 1979 and the first quarter of 1980. We have jurisdiction pursuant to 28 U.S.C. Sec. 1291 , and we affirm. 3 * Statute of Limitations on Assessment 4 DiMeo contends that the district court erred by finding that he waived the…