MEMORANDUM AND ORDER
ELFVIN, District Judge.
Pursuant to 26 U.S.C. § 6672, the Internal Revenue Service ("the IRS") has assessed penalties against plaintiff for failure to pay over withholding taxes due from Motif Construction Corporation and Gardenville Lumber and Supply Company, Inc. for the second, third and fourth quarters of 1974. Plaintiff paid a portion of the assessments and then filed a claim for a refund and a redetermination of the assessments...
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