MEMORANDUM AND ORDER
HOLSCHUH, District Judge.
On November 17, 1982, plaintiffs, taxpayers, filed this action against the Commissioner of Internal Revenue seeking a temporary restraining order and a permanent injunction ordering defendant to refrain from any attempt to collect a penalty assessed against plaintiffs under 26 U.S.C. § 6682. On December 3, 1982, defendant Commissioner filed a motion to dismiss the action. This case is now before the Court...
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