Court will infer an agency relationship between the Debtor and Pluhar. As an agent of the Debtor, Pluhar had the authority to bind the Debtor. Furthermore, the Court finds that Pluhar, as the agent of the Debtor, reasonably relied on the legal opinion of Anderson supported by the Certificate from the seller. Reasonable reliance by a corporate officer on advice of his attorney or accountant in not paying a tax can obviate a finding of willfulness. See Gray Line Co. v. Granquist, 237 F.2d 390, 395 (9th Cir.1956) (refusing to find officer acted -willfully where he relied on advice of competent counsel and tax collector that no tax was due), cert. denied, 353 U.S. 911, 77 S.Ct. 667, 1 L.Ed.2d 664 (1957); Corrosion Systems, 185 Ill.App.3d at 583-84, 133 Ill.Dec. at 650, 541 N.E.2d at 861 (<HOLDING>). IDOR argues that there was no evidence
holding that where defendant knew he had a dangerous weapon and it was possible that an injury would occur he acted recklessly not knowingly under oregon law holding that contractor who knowingly violated contract specifications consciously controlled risk of loss precluding an occurrence holding that a warrant may be vitiated when supporting affidavit intentionally or recklessly misrepresents material facts holding that officers reliance on accountant negated a finding that he acted consciously voluntarily intentionally knowingly or recklessly in his failure to pay tax holding that attempted firstdegree murder may be committed knowingly or intentionally