United States of America v. Kathryn S. Flaim

CourtDistrict Court, E.D. Pennsylvania
DecidedOctober 31, 2025
Docket5:25-cv-01498
StatusUnknown

This text of United States of America v. Kathryn S. Flaim (United States of America v. Kathryn S. Flaim) is published on Counsel Stack Legal Research, covering District Court, E.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States of America v. Kathryn S. Flaim, (E.D. Pa. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF PENNSYLVANIA ____________________________________________

UNITED STATES OF AMERICA, : Plaintiff, : : v. : No. 5:25-cv-1498 : KATHRYN S. FLAIM, : Defendant. : _____________________________________

O P I N I O N United States’ Motion for Summary Judgment, ECF No. 24 – Granted

Joseph F. Leeson, Jr. October 31, 2025 United States District Judge

I. INTRODUCTION The United States of America brings this action pursuant to 26 U.S.C. § 6672, seeking a money judgment against Defendant Kathryn S. Flaim for federal income tax liability. The Government alleges that Flaim willfully failed to collect, account for, and pay over federal employment taxes of Slate Belt Visiting Nurses, LLC, and Slate Belt Home Care, LLC, two businesses in which Flaim held managerial roles. Currently before the Court is the Government’s Motion for Summary Judgment. For the reasons stated below, the Motion for Summary Judgment is granted. II. FACTUAL AND PROCEDURAL BACKGROUND A. Undisputed Material Facts1 The Internal Revenue Service (IRS) assessed Flaim with trust fund recovery penalties for failing to withhold, and pay over, years’ worth of employment taxes for two businesses in which

1 Where a party fails to oppose a summary judgment motion, the facts may be deemed undisputed. See Fed. R. Civ. P. 56(e)(3); Anchorage Assocs. v. V.I. Bd. of Tax Review, 922 F.2d 168, 175 (3d Cir. 1990). Any factual references made in this section are to the Government’s Statement of Undisputed Material Facts (“Pl. SOF”), ECF No. 24-2. she had management roles: Slate Belt Visiting Nurses, LLC, and Slate Belt Home Care, LLC. See United States’ Statement of Undisputed Material Facts (“Pl. SOF”), ECF No. 24-2, ¶ 70. The IRS conducted at least three assessments since 2015, in which it was determined that Flaim has a total outstanding balance of $204,466.54, as of September 29, 2025. See id. at ¶¶ 71-72. i. Slate Belt Visiting Nurses, LLC Flaim began working for Slate Belt Visiting Nurses, LLC (“Visiting Nurses”), a home health aide company mostly owned by her mother, in the early 1990s. See id. at ¶¶ 1-3. Flaim’s responsibilities at Visiting Nurses included “all aspects of the business,” id. at ¶ 4, including

determining financial policy, id. at ¶ 5, authorizing and directing bill payments, id. at ¶ 6, signing tax returns, id. at ¶ 7, authorizing payroll, id. at ¶ 8, and authorizing and making federal tax deposits, id. at ¶ 10. Flaim also had authority to hire and fire employees, though she left this task to others. Id. at ¶ 13. Flaim was one of only two people who could authorize payroll payments for Visiting Nurses. Id. at ¶ 9. Flaim was also the person assigned the PIN numbers and passwords to access the electronic payment system for federal taxes, and to access the business’s bank account. See id. at ¶¶ 11-12. In 2014, Visiting Nurses fell behind on its employment taxes and had outstanding tax liabilities for quarters one through three. See id. at ¶ 14. Flaim became aware of this tax liability

in spring or summer of 2014, and had several contacts, phone calls, and visits with IRS personnel. See id. at ¶¶ 15-17. Flaim cut staff, salaries, and expenses, but Visiting Nurses’ delinquent taxes increased. See id. at ¶¶ 18-20. During this time, Flaim authorized the payment of other creditors besides the IRS, including bills for supplies, utilities, maintenance, insurance, rent, and payroll. See id. at ¶¶ 20-22. Visiting Nurses closed in the mid-2010s. See id. at ¶ 23. ii. Slate Belt Home Care, LLC In 1997, Flaim opened Slate Belt Home Care, LLC (“Home Care”) as a sole proprietorship, but later incorporated it into a limited liability company. Id. at ¶¶ 24-25. Home Care is a member-managed LLC, of which Flaim is the sole member.2 Id. at ¶¶ 26-27. Home Care was designed to complement the work of Visiting Nurses, by providing homemaking and personal care services for clients. Id. at ¶ 28. Flaim “has final authority over all managerial decisions at Home Care,” id. at ¶ 31, including “oversee[ing] financial affairs,” id. at ¶ 49, setting employee salaries, signing rental leases, purchasing equipment, and making IRS

payments, id. at ¶ 50. Flaim opened Home Care’s bank accounts at Fidelity Bank and is the only one with signature authority over the accounts. Id. at ¶¶ 33-38, 40. Only Flaim can authorize or make payments of bills or creditors, payroll, and federal tax deposits. Id. at ¶¶ 41, 43. Home Care receives biweekly payroll reports from a third party employed to assist with processing payroll. Id. at ¶¶ 52-53. The biweekly reports notate “the amount of tax withholdings due to the IRS.” Id. at ¶ 54. Home Care “never had a separate bank account for trust fund taxes, and withheld employment taxes were always comingled with other funds.” Id. at ¶ 39. Home Care’s tax returns are signed either by Flaim, or by Home Care’s General Manager, using a rubber stamp of Flaim’s signature after Flaim’s review and approval. Id. at ¶ 44. Only two tax

returns submitted by Home Care do not contain Flaim’s signature or the rubber stamp: Forms 941 for the second quarter of 2015 and the first quarter of 2016, which Flaim believes were signed and submitted by her mother, using Flaim’s name. Id. at ¶ 45. Forms 941 “list the total employment withholding liability due to the IRS for the quarter.” Id. at ¶ 56.

2 The Government also alleges that “[a]t the beginning of Home Care, bylaws were drawn up which listed Flaim as the only member of the business. These bylaws did not discuss her role, responsibility, or powers as member.” Pl. SOF at ¶ 32 (internal citations omitted). The IRS informed Flaim on several occasions that Home Care had outstanding tax liabilities. Id. at ¶ 57. One of these contacts occurred in March of 2018 and another occurred in May of 2023. Id. at ¶¶ 58-59. In a letter dated May 16, 2023, the IRS informed Flaim of all assessed tax liabilities to date. Id. at ¶ 59. Yet in 2023, Flaim continued to make payments to creditors other than the IRS, including for utilities, rent, payroll, and her personal compensation. Id. at ¶¶ 60-63. It is alleged that Flaim’s personal expenses were charged to Home Care’s business accounts as a form of “owner compensation,” including payments to Flaim’s credit card company, Netflix, her husband’s mortgage, and his personal account, as well as ATM cash

withdrawals from the company account. See id. at ¶¶ 68-69. B. Procedural History On March 20, 2025, Plaintiff, the United States of America (the “Government”), at the request of the Chief Counsel of the IRS, and at the direction of the Attorney General of the United States, brought suit against Defendant Kathryn S. Flaim for unpaid trust fund recovery penalty assessments made against her pursuant to 26 U.S.C. § 6672, along with statutory interest. See Compl., ECF No. 1. On March 21, 2025, the Government filed an Amended Complaint, asking the Court to render a judgment against Flaim for her federal income tax liabilities, pursuant to 26 U.S.C. § 6672, in the amount of $207,215.99 (as of March 17, 2025). See Am.

Compl., ECF No. 4. On May 12, 2025, Flaim filed an Answer after being granted an extension of time by the Court. See Answer, ECF No. 14. On May 27, 2025, the Court issued a Scheduling Order requiring that all dispositive motions be filed no later than October 1, 2025, and scheduling a non-jury trial for November 10, 2025. See ECF No. 15. On August 26, 2025, the matter was referred to Magistrate Judge Pamela A.

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