FINDINGS OF FACT AND CONCLUSIONS OF LAW
PECKHAM, District Judge.
INTRODUCTION
This is a civil tax refund suit filed by Plaintiff Brian Cooke to contest assessments made against him by the Internal Revenue Service ("IRS"). The assessments were made pursuant to 26 U.S.C. § 6672 on the theory that Cooke was a "responsible person" of South Pacific Island Airways ("SPIA") for the last two quarters of 1986 and the first quarter of 1987 and is liable...
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