ORDER
CARROLL, District Judge.
This controversy results from a 1980 IRS assessment against Fred R. Esser, P.C. ("taxpayer or corporation"), a small business corporation formed by Fred R. Esser ("Esser") in 1979 to provide legal services. Esser was the sole incorporator, president, secretary, sole member of the board of directors, and the only attorney providing legal services for the corporation. Esser's wife, Margaret, did all of the clerical work for the...
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