ORDER
H. DALE COOK, District Judge, Sitting by Designation.
This matter came before the Court for trial on March 27, 28, 29 and 30, 1995 on plaintiff, Henry Whitmore's claim for a refund of penalties and interest assessed and collected by the United States, through the Internal Revenue Service, for underpayment of taxes. A jury trial was conducted on plaintiff's claim for refund under 26 U.S.C. § 6653 (the civil fraud penalty section) covering underpayment...
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