This tax case arises from an assessment of trust fund recovery penalties pursuant to 26 U.S.C. (I.R.C.) § 6672 (1994) against two officers of Iowa Malleable Iron Co. (IMI), Jean E. Bisbee and Maurice Warner Green, Jr. In a consolidated case, a jury found Bisbee but not Green liable for the penalty. Bisbee made several procedural challenges to the validity of the assessment against him, which the...
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