MEMORANDUM AND ORDER
CROW, District Judge.
On April 29, 1991, the Internal Revenue Service assessed Rodney Arnett a total penalty under 26 U.S.C. § 6672 in the amount of $21,591.72. In these cases, Arnett and the United States government are embroiled in a battle concerning Arnett's liability under § 6672 for certain unpaid employment withholding taxes of TSP, Inc., a company in which Arnett acted as, inter alia, vice-president and secretary...
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