MEMORANDUM OPINION AND ORDERS GRANTING PLAINTIFF MOATS' MOTION FOR SUMMARY JUDGMENT AND DENYING THE GOVERNMENT'S CROSS-MOTION FOR SUMMARY JUDGMENT
JOHN W. OLIVER, Senior District Judge.
I.
This Section 6672 [26 U.S.C. § 6672] case involves the validity of a 100% penalty assessed against plaintiff Moats in the amount of $29,903.91 to cover withholding taxes of Arlen Trophy Company (Arlen), located in Middlesex, New Jersey, a wholly owned subsidiary...
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