Petitioner was held personally responsible for taxes due for the period April 11, 1982 to September 14, 1982, during which time he was an officer of a corporation organized for the purpose of owning and operating a restaurant. Petitioner had a managerial role in the corporation and was responsible for the payment of its taxes during a portion of the audit period. Petitioner contends, as he did before respondent Tax Appeals Tribunal, that...
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