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JENKINS v. U.S.

No. 08-50T.

TIMOTHY L. JENKINS, Plaintiff, v. THE UNITED STATES, Defendant.

United States Court of Federal Claims.

September 15, 2011.

Attorney(s) appearing for the Case

Jane C. Bergner , Washington, D.C., for plaintiff.

Allison B. Ickovic , Tax Division, United States Department of Justice, Washington, D.C., with whom was Acting Assistant Attorney General John A. DiCicco , for defendant.

OPINION

FRANCIS M. ALLEGRA, Judge.

This tax refund case is before the court following trial in Washington, D.C. At issue is whether plaintiff is liable for a so-called "responsible officer" penalty imposed by section 6672(a) of the Internal Revenue Code of 1986 (26 U.S.C.). For the reasons that follow, the court finds that plaintiff, indeed, was liable for the penalty in question and, therefore, is not entitled to the refund he seeks.

I. FACTS<...

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