MEMORANDUM OF DECISION
HENRY J. BOROFF, Bankruptcy Judge.
Before the Court is a Motion to Authorize Reimbursement of Excess Tax Payments (the "Motion") filed by Frank A. Rizzo and Andrew Michael Rizzo (the "Movants"). The issue to be determined is whether a "responsible individual" under 26 U.S.C. § 6672 who personally pays to the United States (hereinafter the "IRS") some or all of its claim against the estate may be subrogated to that claim...
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