MEMORANDUM OPINION AND ORDER
BABCOCK, District Judge.
Pending before this court is the United States of America's (the United States) motion for summary judgment on its counterclaim based on 26 U.S.C. § 6672 against Harry Scott (Scott) and J.H. Hambric (Hambric). Jurisdiction exists pursuant to 28 U.S.C. § 1346(a)(1).
The motion for summary judgment is granted in favor of the United States against Scott for the entire second and third quarters...
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