Court of Appeals for the Fifth Circuit June 1, 1992, 90-1922 (Robert L. Cash and Evelyn L. Cash v. United States of America, Defendant-Counter v. Randall C. Block, Counter)

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W. EUGENE DAVIS, Circuit Judge:

Taxpayers appeal the district court’s adverse judgment. They argue that the Internal Revenue Service’s levy on accounts receivable of LTS Optical, Inc. (the taxpayers’ corporation) satisfied the corporation’s tax liability, and thereby relieved taxpayers of any liability under § 6672 of the Internal Revenue Code.