MEMORANDUM OF DECISION
ZOBEL, District Judge.
Plaintiff Paul E. Davies ("Davies") brings this action for refund of $600 paid under protest against tax assessments made by the Internal Revenue Service. The six assessments of a total of $20,940.71 were made against Davies individually, pursuant to 26 U.S.C. § 6672 (1982), for federal employment taxes withheld from the wages of employees of Dee-J's, Inc. but never paid to the United States. By counterclaim...
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