DECISION AND ORDER
LARIMER, District Judge.
These are actions by Raymond C. Weidmann (Weidmann), an accountant, for a refund of a "preparer's penalty" assessed against him by the Internal Revenue Service (IRS) pursuant to § 6694(a) of the Internal Revenue Code (Code) for tax returns prepared during the years 1980-1982. There were nineteen separate returns, each of which resulted in penalties over the three-year period. The two actions, Civ. Nos. 84...
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