POLOZOLA, District Judge.
This matter is before the Court on the motion of the defendant United States for summary judgment. The plaintiff, Leon A. Fontenot, filed this suit seeking the refund of $100 which he paid in partial satisfaction of a penalty assessed against him by the United States under 26 U.S.C. § 6672. The total penalty assessed against him was $43,100 for Withholding and FICA taxes due from Allstate Painting, Inc. for the second and third quarters...
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