Was the Third Circuit's standard for willfulness under 26 U.S.C. § 6672(a) too lax for situations that at best are mere negligence in conflict with the standard articulated by the Second and Sixth Circuits?

QUESTIONS PRESENTED 1. Was the Third Circuit’s standard for willfulness : under 26 U.S.C. § 6672(a) too lax for situations that at best are mere negligence in conflict with the standard articulated by the Second and Sixth Circuits? 2. Was summary judgment inappropriate in: light of the record of evidence demonstrating a clear dis_ pute of facts as to the question of the willfulness of the Petitioner? :