MEMORANDUM & ORDER
HAGOPIAN, United States Magistrate Judge.
The instant matter has been referred for the conduct of all proceedings, including trial and entry of judgment with direct appeal to the United States Court of Appeals for the First Circuit. 28 U.S.C. § 636(c). Before the Court is the Plaintiff's claim for a refund of a $3,000.00 penalty, assessed by the Internal Revenue Service under 26 U.S.C. § 6701, plus interest, costs, and attorney...
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