26 U.S.C. § 4103
Certain additional persons liable for tax where willful failure to pay
In any case in which there is a willful failure to pay the tax imposed by section 4041(a)(1) or 4081, each person—
who is an officer, employee, or agent of the taxpayer who is under a duty to assure the payment of such tax and who willfully fails to perform such duty, or
who willfully causes the taxpayer to fail to pay such tax,
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