OPINION
GRIFFIN, Circuit Judge.
Despite the fact that Gaetano Rizzo filed for bankruptcy protection and received a general discharge, the Michigan Department of Treasury ("Treasury") persisted in its claim that Rizzo owed Treasury more than $70,000 in unpaid Michigan Single Business Tax ("SBT"). According to Treasury, Rizzo was personally liable for the unpaid tax because a company for which he had been the responsible corporate officer had failed to pay...
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