PER CURIAM.
Plaintiffs appeal from a district court order granting summary judgment to the government and assessing a $500 frivolous return penalty under 26 U.S.C.A. § 6702(a). The district court also awarded attorneys' fees to the government because plaintiffs' legal position was patently frivolous.
I.
In April 1983, plaintiffs filed separate Forms 1040 for the 1982...
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