OPINION OF THE COURT
PER CURIAM.
Appellant, the United States of America, appeals an order of the United States District Court for the District of New Jersey holding that an Internal Revenue Service ("IRS") assessment of a penalty against Umberto J. Guido, Jr. ("Guido"), under section 6672 of the Internal Revenue Code (the "Code"), was time barred by the three year statute of limitations contained in Code section 6501(a).
Section 6672 of Title 26...
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