FINDINGS OF FACT, DISCUSSION, CONCLUSIONS OF LAW, AND ORDER
HUYETT, District Judge.
Plaintiff, Linda L. Sadowski (now Linda Kemmerer), brought this civil action against the United States of America for a tax refund. The United States had assessed the plaintiff for a one hundred percent civil penalty pursuant to 26 U.S.C. § 6672 for failure to pay federal income taxes withheld during the third quarter of 1980 through the third quarter of 1982 from employees...
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