ORDER
HODGES, Chief Judge.
The parties have filed cross-motions for partial summary judgment. This is a civil action for a refund of $5,400.00 the Plaintiff has paid on a $36,000.00 penalty assessed against him by the Internal Revenue Service pursuant to Title 26, U.S.C. § 6700.
The issue before the Court is one of statutory construction. Section 6700 provides, in pertinent part:
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