MEMORANDUM AND ORDER
GLASSER, Senior District Judge.
Plaintiff Dvora Skoczylas ("Skoczylas" or "plaintiff") brings this action to abate a trust fund recovery penalty that the Internal Revenue Service ("IRS") assessed against her pursuant to § 6672 of the Internal Revenue Code of 1986, as amended (the "Code"), and to recover partial payments she made to satisfy this penalty. The government brings counterclaims...
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