Submitted under Third Circuit Rule 12(6) April 12, 1982.
Rehearing and Rehearing In Banc Denied May 25, 1982.
OPINION OF THE COURT
JAMES HUNTER, III, Circuit Judge:
The Internal Revenue Service (the "IRS") assessed deficiencies in federal income taxes against appellant John C. Raley (the "taxpayer") for the tax years 1972 through 1976. In addition, the IRS assessed Raley a penalty for his failure to pay an estimated tax pursuant to the Internal...
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