ORDER
VAN SICKLE, District Judge.
Plaintiff sues pro se to overturn a civil tax penalty assessed against him under 26 U.S.C. § 6702. Defendants move for judgment on the pleadings or for summary judgment. Because defendants rely on materials outside the pleadings, the Court will treat the motion as a Rule 56, Fed.R.Civ.P., motion for summary judgment.
The material facts are not in dispute. Plaintiff filed an income tax return for 1982 which listed...
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