MEMORANDUM
NORTHROP, Senior District Judge.
On May 17, 1985, the plaintiffs, Lucy and Sheldon Clark (Clarks), instituted action in this Court seeking an abatement of a $500 tax penalty assessed against them by the Internal Revenue Service for filing a "frivolous" tax return. On December 11, 1985 the plaintiffs amended this complaint to include a claim of relief from a second penalty of $500 imposed by the Service for filing a subsequent "frivolous" tax return...
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