Grizaffi v. Federal Savings & Loan Insurance Corp.

refusing to accord collateral estoppel effect to prior state court determination | "clandestine character of the actions of those involved" and "the conversation of the participants" are relevant circumstances in determining whether transaction was narcotics-related | “clandestine character of the actions of those involved” and “the conversation of the participants” are relevant circumstances in determining whether transaction was narcotics-related | “a failure to comply with certain procedural requirements of F.R.Cr.P. 41 has been held not to amount to deprivation of Fourth Amendment rights necessitating suppression” | directive to IRS to apply current payment and prior payments to trust fund liability was not binding on IRS in regard to prior payments | plaintiff seeking a refund of a partial payment of a § 6672 pen alty has the burden of proving that he was not a responsible person | "(T)he threshold question is whether the Trial Judge could conclude, after all the evidence is in, that the prosecution had established the declarant's and the defendant's participation in the conspiracy 'by a fair preponderance of the evidence independent of the hearsay utterances.' " | “[T]he threshold question is whether the Trial Judge could conclude, after all the evidence is' in, that the prosecution had established the declarant’s and the defendant’s participation in the conspiracy ‘by a fair preponderance of the evidence independent of the hearsay utterances.’ ” | responsible person was 50% shareholder, director, and signatory