OPINION
ORRICK, District Judge.
This case presents the question whether under 26 U.S.C. § 3505(a) a person, who is not an employer but who directly pays the wages of an employer's employees, is liable to the United States for the withholding and F.I.C.A. taxes required to be deducted and withheld from such wages by such employer, whether or not he has knowledge that the taxes should be deducted and withheld or that the employer is unable or unwilling...
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