MEMORANDUM AND ORDER
HOLSCHUH, District Judge.
Plaintiff Ronald E. Parkinson brings this action against the United States alleging that the Internal Revenue Service unlawfully assessed him a $500 frivolous return penalty and failed to refund him $3,723 overpaid on his 1982 income tax return. This matter is before the Court on defendants' motion to dismiss or, in the alternative, for summary judgment.
Plaintiff Parkinson signed his 1982 income tax...
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