BOOCHEVER, Circuit Judge:
Ollie B. Hadley was assessed a penalty in the amount of $218,032 for willful failure to pay delinquent withholding taxes under 26 U.S.C. § 6672. The government filed a claim to reduce that assessment to judgment. During the course of pretrial discovery, the government served a request for admissions on Hadley. Hadley failed to respond within 30 days, and the matters were deemed admitted under Fed.R.Civ.P. 36(a). The deemed admissions...
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