MEMORANDUM OF DECISION AND ORDER
NEAHER, District Judge.
Plaintiff ("Roth") commenced this action to obtain a refund of $100 he paid in partial satisfaction of a federal tax assessment and lien levied against him in the sum of $59,723.05. The assessment was made on October 27, 1967, as a 100% penalty pursuant to the provisions of Section 6672 of the Internal Revenue Code of 1954 ("Code"), on the grounds that Roth had willfully failed to collect, truthfully...
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