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KENAGY v. U.S.

No. 90-2620.

942 F.2d 459 (1991)

Karen Kingman KENAGY, Appellant, v. UNITED STATES of America, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided August 6, 1991.

Attorney(s) appearing for the Case

Ronald R. Holliger, argued, for appellant; Robert R. McQuain, Ronald R. Holliger and Dennis A. Boman, Kansas City, Mo., on the brief.

Elizabeth K. Wickstrom, argued, for appellee; Shirley D. Peterson, Gary R. Allen, Charles E. Brookhart and Elizabeth K. Wickstrom, Washington, D.C., on the brief.

Before BOWMAN, Circuit Judge, HENLEY and FRIEDMAN, Senior Circuit Judges.

HENLEY, Senior Circuit Judge.

Appellant-plaintiff, Karen Kingman Kenagy,1 the former office secretary/manager of a small carpet cleaning business, All Pro Carpet Cleaning, Inc. (All Pro), was assessed a responsible person penalty pursuant to 26 U.S.C. § 6672 (1988) (the Internal Revenue Code, hereinafter the "I.R.C." or the "code"). The penalty assessment of $42,859.352 was based on unpaid payroll taxes...

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