BRIGHT, Circuit Judge.
James and Gayle Oppliger appeal from a summary judgment entered against them, which ordered them to pay the United States over $2 million in trust fund recovery penalties under 26 U.S.C. § 6672. The IRS assessed these penalties because the Oppligers' companies, Double O, Inc. ("Double O") and Livestock Feed Company, LLC ("LFC"), withheld taxes from their employees but did not remit those taxes to the government for approximately four years...
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