MEMORANDUM
ROBERT L. TAYLOR, Chief Judge.
This is an action challenging an administrative penalty of $500.00 imposed on plaintiff by the Internal Revenue Service for filing a tax return deemed "frivolous" pursuant to 26 U.S.C. § 6702. Jurisdiction of this cause is conferred upon this Court by virtue of 28 U.S.C. § 1346 and 26 U.S.C. §§ 6703 and 7422. This case is before the Court on defendant...
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