OPINION
FABER, District Judge.
I. Statement of the Case
Plaintiffs Bernard Johnson ("Johnson") and Randy Dixon ("Dixon") brought this civil action against the United States seeking refund of $100.00 each in payments made upon federal tax assessments pursuant to 26 U.S.C. § 6672 ("section 6672"), entry of an order abating any and all claims relative to unremitted withheld tax liabilities of Big J Enterprises, Inc. ("Big J"), and...
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