MEMORANDUM OF DECISION
BLUMENFELD, District Judge, Sitting by Designation
This case began as an action by the plaintiff for refund of $53.77 plus interest and costs which he paid on February 2, 1973 as income taxes withheld from the wages of employees of Take I Productions, Inc. ("Take I"). Thereafter the United States assessed the plaintiff for a 100% civil penalty in the amount of $42,680.20 in lieu of federal income taxes withheld from the wages of employees...
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