MEMORANDUM
WISEMAN, Chief Judge.
This is an action brought under 28 U.S.C. § 1346(a)(1) for recovery of $8,430.40 plus interest and costs which plaintiff Coleman Brown, the administrator of the estate of his deceased sister, alleges was erroneously assessed and collected by the Internal Revenue Service (IRS) as penalties for late filing of an estate tax return and late payment of tax. Having considered the evidence adduced at trial and the arguments...
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