KANNE, Circuit Judge.
The Internal Revenue Code requires employers to withhold federal social security and income taxes from the wages of their employees. See 26 U.S.C. §§ 3102 and 3402. The withheld taxes constitute a special fund held in trust for the benefit of the United States. See 26 U.S.C. § 7501(a); Slodov v. United States,
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