MEMORANDUM OPINION AND ORDER
HARDY, District Judge.
These cases involve common questions of law and fact. The Government has moved for summary judgment on plaintiffs' claims seeking a judicial determination of their liability for penalties assessed by the Internal Revenue Service pursuant to Section 6702 of the Internal Revenue Code (26 U.S. C.). Summary judgment may be granted "if the pleadings ... together with the affidavits, if any, show that there is...
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