a “responsible person” under § 6672 in these circumstances. B. Willfulness 1. Standard of Review As with the previous issue, the government asserts that the determination of willfulness under § 6672 is a question of law subject to de novo review, while Bradshaw argues that it is a question of fact on which the district judge’s ruling can not be overturned unless it is clearly erroneous. Some circuits have held that the ultimate issue of willfulness is subject to de novo review. United States v. McCombs, 30 F.3d at 320 (noting, however, that this is a difficult question that, in similar contexts, has divided the courts for over a century); Thibodeau v. United States, 828 F.2d at 1505-07. Our prior decisions have, however, treated this as an issue of fact. See Taylor, 69 F.3d at 417-18 (<HOLDING>); Denbo, 988 F.2d at 1033 (reviewing jury
holding that we review for clear error the bankruptcy courts factual findings holding that the district court sitting in review of the decision of the bankruptcy court erred in concluding that plaintiffs failure to pay over taxes was willful because the bankruptcy court had made no findings on willfulness we remanded for bankruptcy court findings holding that 28 usc  1961a applies to bankruptcy court judgments because a bankruptcy court is a unit of the district court holding that bankruptcy court may issue proposed findings and conclusions in a core proceeding over which the bankruptcy court does not have constitutional authority holding that the bankruptcy court has the inherent power to award sanctions for badfaith conduct in a bankruptcy court proceeding