OPINION
GRABER, Circuit Judge:
Plaintiff Raymond T. Nakano served as Senior Vice President and Chief Financial Officer of National Airlines, Inc. ("National"), from its founding in 1995 until it filed for Chapter 7 bankruptcy in May 2003. The Internal Revenue Service ("IRS") assessed unpaid excise taxes against Plaintiff personally, pursuant to 26 U.S.C. § 6672. He then brought this civil action against the United States, pursuant to 26 U.S.C. §...
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