MEMORANDUM OPINION AND ORDER
BUCKLO, District Judge.
Richard Pinto was the owner of Pinto Brothers Construction, Inc. ("Pinto Brothers"). Pinto Brothers failed to pay employment taxes out of money withheld from employee wages and was assessed hundreds of thousands of dollars in trust fund tax penalties by the Internal Revenue Service ("IRS"). Richard Pinto was assessed personal liability as a "responsible person" for the trust fund tax penalty under...
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