MEMORANDUM OPINION AND ORDER
BABCOCK, District Judge.
In this action arising under the Internal Revenue Code of the United States (IRC), 26 U.S.C. § 1 et seq., the parties, defendant United States of America (United States) and plaintiff, Reading Ventures, Ltd. (RVL) cross-move for summary judgment pursuant to Fed.R.Civ.P. 56, on RVL's claim for abatement of Internal Revenue Service (IRS) penalties. The motions are adequately briefed and oral argument...
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