KING, Circuit Judge:
The Internal Revenue Service appeals the bankruptcy court's declaratory judgment that it is barred from proceeding against Dudley Davis Taylor by the res judicata effect of his confirmed Chapter 11 plan of reorganization, which purported to fix his liability for a 26 U.S.C. § 6672 penalty at zero. The district court affirmed the judgment of the bankruptcy court. We reverse.
I. FACTUAL AND PROCEDURAL BACKGROUND
In August...
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