MEMORANDUM OPINION AND ORDER
DECKER, District Judge.
Plaintiff, John Brockhouse ("Brockhouse"), has brought this pro se action against the United States of America ("United States") seeking a refund of $15.00 paid toward the satisfaction of a $100.00 tax preparer penalty assessed against him by the Internal Revenue Service ("IRS"). The penalty was imposed on Brockhouse, a Certified Public Accountant, under 26 U.S.C. § 6694(a) ("section 6694(a...
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