MEMORANDUM OPINION AND ORDER
SIMPSON, District Judge.
In this case, the United States seeks to collect unpaid penalties assessed against the defendants under 26 U.S.C. § 6695. The original assessment was for $2,661,150 of which the defendants paid $9,705.23. The unpaid balance the United States seeks in its complaint is $2,651,444.70.
In May, 1990, the IRS sent notice to defendants that their liability for $2,650,725 of the outstanding unpaid...
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