MARKEY, Chief Judge.
Appeal from a judgment of the United States Claims Court, 3 Cl.Ct. 595 (1983), holding Dudley J. Godfrey, Jr. (Godfrey) liable for $159,361.26 of unpaid accrued taxes of Career Academies, Inc. (Career) pursuant to Internal Revenue Code section 6672, the 100 percent tax penalty provision.
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