Burton B. Paddock v. C. J. Siemoneit

Summary

The Texas Supreme Court held that C. J. Siemoneit did not breach his fiduciary duty by borrowing corporate funds, so no constructive trust could be imposed for the trustee in bankruptcy. The Court also held that Siemoneit was liable for the civil tax penalty under 26 U.S.C. §2707(a) because his failure to pay was intentional and deliberate, but the government lien could not attach to his wife's separate homestead interest.