MEMORANDUM
TIMOTHY J. MAHONEY, Chief Judge.
Evidentiary hearing was held on March 9, 1988, concerning the liability of debtor, Theodore V. Olson, to the United States through the Internal Revenue Service for an assessment pursuant to 26 U.S.C. § 6672 in the amount of $184,220.96. Robert Creager of Berry, Anderson, Creager & Wittstruck, P.C., Lincoln, Nebraska, appeared on behalf of the debtor; Frank Heinish of Geneva, Nebraska, and William Needler...
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