CHAMBERS, Circuit Judge:
Appellant Maggy filed suit against the United States for refund of $24.32 which he had paid in partial satisfaction of a $32,060.49 tax penalty assessed against him pursuant to 26 U.S.C. §§ 6671-72. He additionally prayed for indemnification from third party defendants for any further liability on the balance of the assessments. After a trial to the court, judgment in the amount of $32,036.17 was entered in favor of the United States...
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