MEMORANDUM
McCUNE, District Judge.
This is a federal tax case. The government asserts liability against North Side Deposit Bank (North Side) for unpaid withholding taxes (WT), 26 U.S.C. §§ 3401, et seq., and Federal Insurance Contributions Act (FICA), 26 U.S.C. §§ 3101, et seq., of
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