In Slodov v. United States, the Supreme Court ruled on the liability of a new corporate director for unpaid taxes withheld from employees' wages by previous management. The IRS argued that under Section 6672 of the Internal Revenue Code, any person required to collect and pay over such taxes who willfully fails to do so is liable for a penalty equal to the total amount of tax due. However, Slodov contended he was not responsible as he had no knowledge or control over funds collected before his tenure began. The court sided with Slodov in an 8-1 decision stating that "responsible persons" are only those who have significant control over financial decisions and can therefore be held accountable for non-payment of withholding taxes. It further clarified that these individuals could only be held liable if they acted willfully - either through deliberate choice or reckless disregard - in failing to collect or pay these taxes. This ruling established important precedent regarding corporate responsibility and liability for past debts when leadership changes occur.

In the dissenting opinion for Slodov v. United States, Justice Blackmun argued that the majority's decision was a departure from established precedent and an unwarranted expansion of liability protection for corporate officers in cases involving unpaid taxes. He contended that the Internal Revenue Code did not distinguish between "collected" and "unpaid" withholding taxes, thus all responsible persons should be liable regardless of when they assumed their duties or whether they were aware of any tax delinquency at the time. The justice also expressed concern about potential abuses by corporations who could strategically appoint new officers to shield themselves from penalty after failing to pay over withheld taxes. In his view, this interpretation undermined Congress' intent to ensure prompt payment of these funds held in trust by employers on behalf of employees and government.