MEMORANDUM OPINION AND ORDER
DECKER, District Judge.
Plaintiff, Orris Ruth (Ruth), brought this action to contest an Internal Revenue Service (IRS) tax assessment. As is the common practice in these cases, plaintiff paid a small amount of the assessment and sued for a refund. The government counterclaimed for the remainder of the assessment.
The assessment is based on the IRS's finding that plaintiff was a "responsible person" at Custom Packaging...
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