Counselor, your advice?

The CPA: So, how is your appeal going with the IRS?
The Client: They are still going after me for the unpaid $119,000 in payroll taxes.
The CPA: What evidence do they have on you?
The Client: I signed the paychecks, I made the phone calls and I am an officer in the corporation. But I didn't know what I was doing!
The CPA: What's your lawyer's say?
The Client: I'm naive.