§ 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—
(1)
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
shall be jointly and severally liable with the taxpayer for the tax to which such failure relates.