Rehearing and Rehearing En Banc Denied June 1, 1993.
KING, Circuit Judge:
The Internal Revenue Service appeals from the judgment of the district court denying its motion for judgment as a matter of law on the issue of Richard D. Barnett's liability under 26 U.S.C. § 6672(a). Because we conclude that the district court erred in denying the motion, we reverse and remand the action for further proceedings consistent with this opinion.
I.
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