MEMORANDUM OPINION
LATCHUM, Senior District Judge.
I. INTRODUCTION
Defendants, Ellin & Tucker, Chartered ("Ellin & Tucker") and Joel Kaye ("Kaye"), have moved for summary judgment, (Docket Item ["D.I."] 37), against plaintiff Steven R. Alten ("Alten"), pursuant to Rule 56 of the Federal Rules of Civil Procedure. Plaintiff filed this suit to recover over $140,000.00 of tax penalties imposed upon him personally by the Internal Revenue...
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