OPINION OF THE COURT
JAMES HUNTER, III, Circuit Judge:
The sole issue on this appeal is the determination of the proper method by which civil tax fraud penalties are to be assessed under 26 U.S.C. § 6653. The Internal Revenue Service ("IRS") assessed a 50% fraud penalty on the difference between taxpayers' true tax liability and the tax liability shown on taxpayers' original tax returns. The district court upheld this method of computation and we affirm...
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