MEMORANDUM ORDER
KEADY, District Judge.
In this tax refund case, plaintiff, David Michael Reid, sues defendant, United States of America, for a refund of $100 which was part of a 100% penalty assessed under 26 U.S.C. § 6672 against him as a responsible person who wilfully failed to pay withheld employment taxes over to the IRS. The United States counterclaimed against Reid for the balance of the 100% penalty. Reid then filed a third-party complaint...
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