Court of Appeals for the Seventh Circuit April 21, 1997, 95-3922 (United States v. Moon H. Kim)

COFFEY, Circuit Judge.

Defendant Moon H. Kim (Kim) was one of three co-owners of a corporation that failed to pay federal employee withholding taxes during certain segments of the years 1989 to 1991. Kim was assessed a penalty by the IRS and he refused to pay the same, forcing the government to commence this civil action to reduce the assessment to a judgment.