DECISION AND ORDER DENYING DEFENDANT'S MOTION FOR SUMMARY JUDGMENT
MCMAHON, District Judge.
In May 2003, the Internal Revenue Service assessed a trust fund recovery penalty against Manfred Reiff ("Reiff') as a responsible person pursuant to 26 U.S.C. § 6672 for the unpaid withholding tax obligations of LuuLuu.com, Inc. ("LuuLuu"). Over the last two quarters of 2000 and the first quarter of 2001, LuuLuu failed to pay approximately $193, 571.00 in federal...
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