On May 17, 1983, appellant, James M. Thomas, was assessed a $500 penalty for filing a frivolous 1982 income tax return. See 26 U.S.C. § 6702. Thomas did not receive the notice and demand for payment of the penalty until June 28, 1983, apparently because the Internal Revenue Service (IRS) had used an incorrect zip code. However, the zip code used was that given by Thomas on his 1982...
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