MEMORANDUM OPINION
KENNEDY, District Judge.
Plaintiffs Peter Ackerman and Joanne Leedom-Ackerman, husband and wife, bring these actions against the United States of America for refund of (1) income tax (Ackerman I, Civil Action 08-00279); (2) accuracy-related penalties (Ackerman IV, Civil Action 08-01136); and (3) failure-to-pay penalties (Ackerman III, Civil Action 08-00722), all for tax years 1997 through 2003, and all allegedly erroneously...
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