MOORE, Senior Circuit Judge.
The United States of America (the "Government") plaintiff-appellant, brought this suit to reduce to judgment a penalty of $16,414.69 which had been assessed against Richard L. Kroll, as Executor of the Estate of Gertrude O'Reilly ("Kroll"), defendant-appellee, for failure to file an estate tax return within the period provided by law. No opinion, findings of fact or conclusions of law exist other than as delivered orally by the District...
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