OPINION RE MOTION FOR SUMMARY JUDGMENT
HILLMAN, District Judge.
Plaintiffs bring this action pursuant to 26 U.S.C. § 6703(c)(2) challenging the assessment of an income tax penalty against them with respect to their 1982 income tax return.
Plaintiffs, Scott and Cynthia House, filed a 1982 Form 1040 joint income tax return dated March 30, 1983. This form was accompanied by four W-2 wage and tax statements for 1980...
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