MEMORANDUM
KEITH M. LUNDIN, Bankruptcy Judge.
The issue is whether a corporate officer who pays a 100% tax penalty under 26 U.S.C. § 6672 acquires by subrogation a nondischargeable claim against the debtor, another corporate officer against whom the IRS might also have imposed "responsible person" liability. There is no right of subrogation.
I.
The debtor and Patterson were directors, officers and shareholders of A-Team Sports, Inc...
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