MEMORANDUM OPINION
H. FRANKLIN WATERS, Chief Judge.
This case is before the court on a motion for summary judgment filed by the plaintiff, Roberta Lamb. Lamb filed a complaint against the United States of America on May 16, 1991, alleging that the government had improperly assessed a penalty of $26,000.00 against her for purported violations of Section 6701 of the Internal Revenue Code, 26 U.S.C. § 6701. In her motion for summary judgment Lamb asserts...
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