MEMORANDUM
NORTHROP, Senior District Judge.
Plaintiffs Edward and Dorothy Snyder filed their action in this Court on June 14, 1988 seeking the abatement of a $500 tax penalty assessed against them by the Internal Revenue Service (IRS) for filing a frivolous tax return under 26 U.S.C. § 6702 (1988). The plaintiffs also seek the refund of 15% of the penalty which they paid to the IRS in order to challenge the assessment. Pending before the Court are the...
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