MEMORANDUM AND ORDER
BENSON, Senior District Judge.
John Ronsberg initiated this suit against the Internal Revenue Service (IRS) of the United States after he was assessed a one-hundred percent penalty pursuant to 26 I.R.C. § 6672. Ronsberg was assessed the penalty in his capacity as a "responsible person" for purposes of collecting withholding and employment taxes of Pavement Maintenance, Inc. (PMI). The matter is currently before the court on plaintiff...
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