Western Management, Inc. v. United States

*107OPINION

NANCY B. FIRESTONE, Judge.

At issue in this case are “withholding taxes, withholding tax penalty assessments, Federal Insurance Contributions Act (‘FICA’) taxes, hospital insurance taxes (Medicare), penalties, interest, and damages” in connection with taxes allegedly owed by the individual plaintiffs and Western Management, Inc. (“WMI”) for tax year 1994 and the first quarter of 1995. Compl. ¶ A. The plaintiffs claim that they do not owe these taxes and are entitled to a refund of amounts the individual plaintiffs have paid for the tax periods in question. In the counterclaim, the…