MEMORANDUM OPINION AND ORDER
LAMBROS, District Judge.
Plaintiff Charles L. Hutchinson brings this action pursuant to 28 U.S.C. § 1346(a)(1) to recover withholding taxes paid by him to the Internal Revenue Service (IRS) and for a declaration that an assessment made against him by the IRS pursuant to 26 U.S.C. § 6672 is illegal and improper. The United States has filed a counterclaim to enforce payment...
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