Plaintiff Eastman Machine Company ("Eastman") appeals from a judgment of the United States District Court for the Western District of New York, John T. Elfvin, Judge, dismissing its complaint to recover $229,932 in income tax penalties paid to the Internal Revenue Service ("IRS") pursuant to § 6653 of the Internal Revenue Code of 1954 ("Code"), 26 U.S.C. § 6653 (1976), as a penalty...
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