OPINION AND ORDER
THEIS, Senior District Judge.
This is an action by Robert J. Gray [Gray] to recover a tax penalty assessed against him pursuant to 26 U.S.C. § 6672 for failure to pay to the government federal employment taxes withheld from employees' wages. Defendant United States of America [United States] has filed a counterclaim for the balance of the tax penalty levied against Gray. This case is currently before the Court on the motion of the...
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