MANION, Circuit Judge.
The Internal Revenue Service assessed a $391,500 penalty against Datamatic Services, Inc. (Datamatic). Datamatic filed an administrative claim for refund, which was denied. Datamatic then filed this action for refund in federal court. A jury returned a verdict against Datamatic, imposing a penalty of $400,000. The district judge reduced the penalty to $391,500, the original amount. Datamatic appeals, and we affirm.
I.
In April...
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