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HAGEN v. U.S.

Civ. No. AMD 05-1040.

485 F.Supp.2d 622 (2007)

Richard K. HAGEN, Plaintiff/Counter-Defendant v. UNITED STATES of America, Defendant/Counter-Defendant/Counter-Plaintiff.

United States District Court, D. Maryland.

April 30, 2007.

Attorney(s) appearing for the Case

Franklin Joseph Gormley, F. Joseph Gormley Esq., Attorney at Law, Annapolis, MD, Robert Beatson, II, Law Offices of Robert Beatson II, Potomac, MD, for Plaintiff/Counter-Defendant.

MEMORANDUM OPINION

DAVIS, District Judge.

Plaintiff Richard K. Hagen filed this tax refund action after paying a portion of the amount allegedly due under a trust fund recovery penalty for unpaid payroll withholding taxes for American Quantum Cycles, Inc. ("Quantum"), assessed against him pursuant to 26 U.S.C. § 6672. The government counterclaimed for a total of $274,918 in unpaid assessments, penalties and interest for the fourth quarter of 1999 and...

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