MEMORANDUM OPINION AND ORDER
ASPEN, District Judge:
In this civil tax case plaintiff Dennis Mulee ("Mulee") seeks a refund of $4,731.89 he paid against an assessment of $94,639.96 by the Internal Revenue Service ("IRS") pursuant to section 6672 of the Internal Revenue Code ("IRC") of 1954, 26 U.S.C. § 6672 (1982), as a responsible person of the Denalco Corporation ("Denalco") for the entire third quarter of 1981 and part of the fourth quarter of 1981...
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