In Re Neal

ORDER

MOODY, District Judge.

Peay’s Detective Agency failed to pay over withholding taxes to the United States for eight quarters between 1982 and 1985. The United States assessed the full delinquent amount against Denise Neal. See 26 U.S.C. § 6672(a). 1 Neal, who was in bankruptcy, petitioned the bankruptcy court to determine the extent of her liability. See 11 U.S.C. § 505 (bankruptcy court empowered to determine debtor’s tax liabilities). The bankruptcy court conducted an evidentiary hearing and determined that Neal became responsible, for § 6672(a) purposes, in April, 1984. It concluded…