MEMORANDUM OPINION AND ORDER
KANE, District Judge.
Plaintiff Reed seeks a refund of $75 which he paid as a partial penalty for filing a frivolous tax return. The government assessed the penalty pursuant to the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA). The government's position then and now is that Reed filed a 1982 tax return which does not contain information on which the correctness of the self-assessment may be judged and that his conduct...
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