FRIENDLY, Circuit Judge:
On November 7, 1963, the Internal Revenue Service made 100% penalty assessments under § 6672 of the Internal Revenue Code against appellant Manuel E. Kulukundis in the amount of $732,427.13 and against appellant M. Michael Kulukundis in the amount of $324,161.55 because of the failure of certain corporations of which they were alleged to be responsible officers to pay withholding taxes. A month later the United States commenced an action...
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