MEMORANDUM OPINION
MOTLEY, District Judge.
This is an action pursuant to Sections 7402(a) and 7403 of the Internal Revenue Code of 1954, as amended, for recovery of withholding taxes due as a result of wage payments made during the first and second quarters of 1969.
The defendant, William Armbruster, was the president of Edgewood Furniture Co., Inc., (Edgewood), and had run the company since he founded it in 1947. Encountering serious financial difficulties...
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