are relatively few and far between.” Id. at 1456. “[T]he rationale for the broad net of § 6672 responsibility serves a valuable prophylactic purpose: it encourages officers, directors, and other high-level employees to stay abreast of the company’s withholding and payment of employee’s taxes.” Id. at 1456-57. This “broad net” of liability can extend beyond the most responsible person; in reality, multiple persons can be deemed responsible for purposes of § 6672 liability. Id. at 1455. For instance, though an employee may not have the final say as to financial disbursements made by the employer, where the employee nonetheless has “significant control over disbursements[, it] is sufficient for section 6672 liability to attach.” Neckles v. United States, 579 F.2d 938, 940 (5th Cir.1978) (<HOLDING>). Based on the facts of this Case, the Court
holding that individuals assumption of the role of president of the corporation and her authority to sign documents on behalf of the corporation demonstrate that she had the requisite control over the corporation for purposes of finding individual liability under section 5a recognizing that when a corporation is insolvent the trust fund doctrine fundamentally alters the relationship between a corporation its shareholders and its creditors and that corporate or shareholder ratification does not apply to creditors who would be prejudiced thereby holding that nonofficer nonemployee who was in reality a de facto officer or employee of corporation and who had significant control over disbursements made by the corporation was responsible person for purposes of  6672 liability where he had failed to insure payment of trust fund taxes of corporation while continuing payment of other corporate creditors holding that the trust fund and denuding theories of recovery were considered to belong to the debtor corporation because each action was created for the benefit of the corporation ie to vindicate injury to the corporation caused by improper actions by control persons holding that claims of corporation vest in corporation