PER CURIAM.
This appeal has been referred to a panel of the Court pursuant to Rule 9(a), Rules of the Sixth Circuit. After examination of the record and the briefs filed by the parties, the panel agrees unanimously that oral argument is not needed. Fed.R.App.P. 34(a).
Mr. Brennan appeals from the district court's judgment which dismissed his action to recover a portion of a fine paid pursuant to I.R.C. § 6702.
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