MEMORANDUM AND ORDER
HOLSCHUH, District Judge.
This appeal arises out of the collection and payment of trust fund taxes by a corporation, Village Junction Restaurant, Inc., formerly owned by Jon Ford. Mr. Ford, the sole shareholder, was responsible for collecting and remitting the trust fund taxes to the Internal Revenue Service. Believing that these taxes had not been paid in full following the sale of the corporation in August 1986, the IRS assessed...
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