MEMORANDUM
RICHARD L. WILLIAMS, District Judge.
Plaintiff, Dr. E. Leon Cooper, has filed suit seeking a refund in the amount of $5,334.00 paid towards the satisfaction of $147,268.33 Section 6672, Internal Revenue Code, penalty assessed against him. The United States has counterclaimed for the balance of the assessment plus interest.
Jurisdiction over plaintiff's claim against the United States is present under 28 U.S.C. § 1346(a)(1). Jurisdiction...
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