MEMORANDUM OPINION
ACKER, District Judge.
This is an action brought pursuant to 26 U.S.C. § 6703(c), by D.J. Weir, pro se. Section 6703(c) is a procedural statute which first became effective on September 3, 1982. It provides that a person against whom a penalty pursuant to 26 U.S.C. § 6700 has been assessed by the Secretary of the Treasury as a result of the person's alleged participation in the formation or selling of an abusive tax shelter...
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