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.
(Added Pub. L. 101–508, title XI, § 11212(c), Nov. 5, 1990, 104 Stat. 1388–431; amended Pub. L. 103–66, title XIII, § 13242(d)(1), Aug. 10, 1993, 107 Stat. 522; Pub. L. 108–357, title VIII, § 853(d)(2)(F), Oct. 22, 2004, 118 Stat. 1613.)