ORDER DENYING PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT
MALONEY, District Judge.
Before the Court is Plaintiff's March 5, 1993, motion for summary judgment. Defendant responded on April 23, 1993. Plaintiff replied. The Court, having considered the motion and the parties briefs, is of the opinion that the motion should be denied.
BACKGROUND
This case involves civil tax penalties assessed by the Internal Revenue Service against Plaintiff...
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