Overland Nat'l Bank of Grand Island v. Theodore V. Olson (In re Olson), Ch. 11, BK85-1085, A85-181
Reported at 101 B.R. 128. Debtor, as company owner, president, & chief operating officer, was "responsible party" for non-payment of payroll taxes, and, because funds that could have been used for taxes went to pay other debts, his conduct was willful.