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SULLIVAN v. UNITED STATES

No. 85-1649.

788 F.2d 813 (1986)

Grant W. SULLIVAN, Plaintiff, Appellant, v. UNITED STATES of America, Defendant, Appellee.

United States Court of Appeals, First Circuit.

Decided April 18, 1986.

Attorney(s) appearing for the Case

Grant W. Sullivan, pro se.

Roger M. Olsen, Acting Asst. Atty. Gen., Michael L. Paup, Gary R. Allen, John P. Griffin, Tax Division, Dept. of Justice, Washington, D.C., and Richard V. Wiebusch, U.S. Atty., Concord, N.H., on brief for defendant, appellee.

Before CAMPBELL, Chief Judge, COFFIN and BOWNES, Circuit Judges.

PER CURIAM.

Grant Sullivan filed suit in district court against the United States, seeking a refund of his partial payment of a civil penalty that the Internal Revenue Service (IRS) assessed against him, and a determination that the penalty should not have been assessed. The district court dismissed his complaint for failure to state a claim upon which relief could be granted. Sullivan appeals from that dismissal. We affirm.

In April, 1984, Sullivan filed...

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