GREEN, District Judge.
In this action issues have arisen regarding the liability of plaintiffs for penalties under §§ 1718(c) and 3612(d), I.R.C.1939.
The assessment made against plaintiffs included a 100% penalty under § 1718(c). Plaintiffs have challenged the applicability of this provision herein. The Government, in its answer, alleges that § 1718(c) applies, but in the alternative contends that if § 1718(c) is not applicable, then...
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