PER CURIAM.
Defendant-Appellant the United States of America ("the government") seeks to uphold an assessment of a penalty tax under 26 U.S.C. § 6672 against Plaintiff-Appellee David R. Stallard for nonpayment of federal taxes withheld from employees. Stallard paid a nominal sum on this tax, then brought the instant case in federal district court to claim a refund and to remove two federal tax liens based on this assessment. The district court granted summary...
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