On Certiorari to the Utah Court of Appeals.
PARRISH, Justice:
¶ 1 The Utah State Tax Commission (the "Commission") argues that the Utah Court of Appeals misinterpreted Utah Code section 59-1-302 in reversing the Commission's decision to personally assess Eric Stevenson for withholding taxes owed by Tower Communications, Inc. ("Tower"). We affirm in part and reverse in part, concluding that Stevenson was not willful in failing to collect the unpaid taxes...
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