MEMORANDUM OPINION AND ORDER
TOM S. LEE, District Judge.
On August 12, 1985, the Internal Revenue Service assessed penalties against the plaintiff, Allen G. Reno, totalling $452,000 pursuant to 26 U.S.C. § 6700. Reno paid a portion of the penalty and then instituted the present action to contest the penalty assessment on the basis that his activities were not violative of section 6700 and claiming alternatively that the amount of the penalty assessed...
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