ARTHUR J. STANLEY, Jr., Chief Judge.
In this action, the United States seeks to recover from E. Frank Allbritten, an officer of Frank Allbritten Motors, Inc. and K-Mo Parts, Inc., the amount of income taxes and social security taxes withheld from wages of employees of the two corporations but not paid over to the United States. The action is predicated on 26 U.S.C.A. § 6672, Int.Rev.Code of
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