MEMORANDUM AND ORDER
SINGLETON, Chief Judge.
This is an action for actual and punitive damages brought by plaintiff, Dougal C. Pope, against Defendant, Ms. Jacqueline Horgan, an employee of the Internal Revenue Service, arising from defendants recommendation that plaintiff be assessed a penalty for negligent preparation of his client's tax return. Defendant moved this court to dismiss plaintiff's amended complaint or for summary judgment upon the grounds...
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