ORDER
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 respective parties, this panel agrees unanimously that oral argument is not needed. Rule 34(a), Federal Rules of Appellate Procedure.
The appellants are appealing the summary judgment which sustained the imposition of a $500.00 penalty levied pursuant to 26 U.S.C. &...
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