Submitted on the Briefs Pursuant to Tenth Circuit Rule 9.
PER CURIAM.
This three-judge panel has determined unanimously that oral argument would not be of material assistance in the determination of this appeal. See Fed.R.App.P. 34(a); Tenth Circuit R. 10(e). The cause is therefore ordered submitted without oral argument.
William A. Mertsching appeals a federal district court order dismissing his 26 U.S.C. § 6694(c)
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