Notice: Eighth Circuit Rule 28a(k) Governs Citation of Unpublished Opinions and Provides That No Party May Cite an Opinion Not Intended for Publication Unless the Cases Are Related by Identity Between the Parties or the Causes of Action.richard L. Matykiewicz; William F. Koepp, Plaintiffs-appellants, v. United States of America, Defendant-counter Claimant-appellee, v. Paul F. Bitter, Counter-defendant, 19 F.3d 1437 (8th Cir. 1994)

This is an appeal from a summary judgment entered by the district court¹  in favor of the government in appellants' action to recover certain amounts paid in partial satisfaction of an assessment against them pursuant to Section 6672 of the Internal Revenue Code (26 U.S.C. § 6672) for the willful failure to collect, truthfully account for, and pay over to the United States certain withheld employee income and FICA taxes.

Finding no error of law in the district court's decision, we affirm the summary judgment on the basis of the district court's memorandum opinion. See 8th Cir. Rule 47B.