OPINION
MILES, Senior District Judge.
This is an action for a refund of money paid to the Internal Revenue Service (IRS) as a civil penalty assessed pursuant to 26 U.S.C. § 6700. That section provides for the imposition of a penalty on those who promote "abusive tax shelters." The $32,000 penalty assessed against plaintiff resulted from his alleged involvement with a tax shelter known as O.E.C. Leasing Corporation (OEC). This matter is presently before...
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