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DALTON v. U.S.

No. 85-2225.

800 F.2d 1316 (1986)

Susan P. DALTON, and Bob Warren, Appellants, v. UNITED STATES of America, Appellee.

United States Court of Appeals, Fourth Circuit.

Decided September 17, 1986.

Rehearing and Rehearing Denied October 30, 1986.

Attorney(s) appearing for the Case

Bob Warren and C. Frank Goldsmith, Jr., Marion, N.C., for appellants.

James H. Love (Roger M. Olsen and Glenn L. Archer, Jr., Asst. Attys. Gen., Michael L. Paup, Chief Appellate Section, Tax Div., Gary R. Allen, Tax Div. Washington, D.C., on brief), for appellee.

Before PHILLIPS and MURNAGHAN, Circuit Judges, and BUTZNER, Senior Circuit Judge.

Rehearing and Rehearing En Banc Denied October 30, 1986.

BUTZNER, Senior Circuit Judge.

Susan P. Dalton appeals from a summary judgment entered for the United States denying her a refund of a $500 penalty imposed pursuant to 26 U.S.C. § 6702(a) (1982) for filing a frivolous income tax return in which she claimed a credit for federal military expenditures to which she objected. Bob Warren, the taxpayer's attorney...

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