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HARRIS v. U.S.

No. 97-5180.

175 F.3d 1318 (1999)

June HARRIS, Plaintiff-Counter-Defendant-Appellee Cross-Appellant, v. UNITED STATES of America, Defendant-Counter-Claimant-Third-Party Plaintiff-Appellant, Cross-Appellee, v. Oscar Lussier Harris, Third-Party Defendant.

United States Court of Appeals, Eleventh Circuit.

May 21, 1999.

Attorney(s) appearing for the Case

Mark Stier, Pamela C. Berry, Steven W. Parks, Loretta C. Argrett, Richard Farber, United States Department of Justice, Tax Division, Washington, DC, for United States of America.

Edward Paul Phillips, Coral Springs, FL, for June Harris.

Before TJOFLAT, BARKETT and MARCUS, Circuit Judges.

PER CURIAM:

Under section 6672 of the Internal Revenue Code (26 U.S.C.), any officer or employee of a corporation who is responsible for the collection or payment of federal employment taxes (a "responsible person") who willfully fails to pay such taxes is liable for a penalty equal to the unpaid amount.1 Pursuant to this statute, the Internal Revenue Service made penalty assessments for unpaid taxes in the amount of $86,421.37 against...

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