MEMORANDUM OPINION
THOMAS M. TWARDOWSKI, Bankruptcy Judge.
Morysville Body Works, Inc. ("debtor") has filed a "Petition to Stay" the Internal Revenue Service ("I.R.S.") from collecting from debtor's president and sole shareholder, Ronald G. Updegrave ("Updegrave") the 100% penalty provided by 28 U.S.C. § 6672 arising from debtor's failure to pay
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