MEMORANDUM OPINION
RALPH G. THOMPSON, District Judge.
Plaintiff commenced this action seeking the recovery of funds paid to the Internal Revenue Service. Plaintiff alleges that the District Director of the Internal Revenue Service in Philadelphia, Pennsylvania assessed a 100% penalty in the amount of $13,132.81 against plaintiff "as a person required to collect, account for, and pay over withheld taxes" for Land Developers, Inc. Against this assessment the...
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