SCHROEDER, Circuit Judge.
In this government tax appeal we must decide whether the IRS properly assessed a $500 penalty against each of the three appellees for filing a frivolous return within the meaning of 26 U.S.C. § 6702. The appeal raises a novel question concerning Congress' use of the word "self-assessment" in that section. There are no material issues of fact.
Congress passed the statute as part of the Tax Equity and Fiscal Responsibility Act...
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