OPINION OF THE COURT
PADOVA, Senior District Judge.
James and Theresa DeMuro ("the DeMuros") owned TAD Associates, LLC ("TAD"), an engineering and surveying company in New Jersey. Between 2002 and 2008, TAD failed to pay over to the IRS more than half a million dollars in taxes that it had withheld from its employees' paychecks. As the owners and managers of TAD, the DeMuros were convicted after a jury trial of conspiracy to defraud the United States, in...
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