OPINION
MOTZ, District Judge.
This action has been instituted against the United States of America by Wallace J. Parr under 26 U.S.C. Section 7422 (1982) to recover taxes and penalties alleged to have been erroneously assessed against him. The Government has counterclaimed to recover interest that has accrued on the assessment and has now moved for summary judgment with respect to both the claim and the counterclaim.
The assessment in question is...
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