1312

Any person required to collect, truthfully account for, and pay over any tax imposed by this subtitle or the Virgin Islands income tax law who willfully fails to collect such tax, or truthfully account for and pay over such tax, or willfully attempts in any manner to evade or defeat any such tax or the payment thereof, shall, in addition to other penalties provided by law, be liable to a penalty equal to the total amount of the tax evaded, or not collected, or not accounted for and paid over. No penalty shall be imposed under section 1283 of this title for any offense to which this section is applicable.