ORDER DENYING MOTION FOR RECONSIDERATION ORDER TAXING FEES AND COSTS AND ORDER DIRECTING CLERK TO ENTER JUDGMENT
JULIA SMITH GIBBONS, Circuit Judge.
Plaintiff, William Carroll, filed a complaint seeking to invalidate the determination by the Internal Revenue Service (IRS) to proceed with collection by levy on the penalty imposed pursuant to 26 U.S.C. § 6702(a). On May 29, 2002, the court granted the defendant's motion for summary judgment after determining...
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