OPINION
JAMES D. GREGG, Bankruptcy Judge.
I. ISSUES
The cross motions for summary judgment in this adversary proceeding raise three issues involving the liability of the Debtors for failure to account for and pay over various taxes to the government. First, whether the Debtors are each responsible persons, within the meaning of 26 U.S.C. § 6672 (hereinafter "I.R.C."), who were required, and willfully failed, to collect, account for, and pay...
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