PARKER, Circuit Judge:
Counterclaim defendants Petrus J. Winter, Steven Romer, and Rita Romer appeal from a judgment of the United States District Court for the Southern District of New York, (Kevin Thomas Duffy, Judge), entered February 19, 1998, finding them personally liable for a tax assessment of $93,592.97 pursuant to 26 U.S.C. § 6672(a) based on the failure of Atlas Protective Services to remit withholding taxes to the Internal Revenue Service as required...
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