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FERGUSON v. U.S.

No. 06-1774.

484 F.3d 1068 (2007)

Donald R. FERGUSON, Plaintiff, v. UNITED STATES of America, Defendant/Appellee, v. Richard Musal, Third Party Defendant/Appellant, Nicholas P. Miller, Third Party Defendant.

United States Court of Appeals, Eighth Circuit.

Filed: April 27, 2007.

Attorney(s) appearing for the Case

Ronald Leigh Mountsier, argued, Des Moines, IA, for appellant.

Kenneth W. Rosenberg, argued, U.S. Dept. of Justice, Tax Division, Washington, DC, for appellee.

Before WOLLMAN and MELLOY, Circuit Judges, and NANGLE, District Judge.

WOLLMAN, Circuit Judge.

This case arises from an assessment of trust fund recovery penalties pursuant to 26 U.S.C. § 6672 against Richard Musal and several other individuals involved in the operation of AccessAir, Inc. (AccessAir). Musal appeals from the district court's2 grant of summary judgment, which found Musal to be a responsible person under § 6672. Musal also appeals from the...

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