MEMORANDUM OPINION AND ORDER
NORDBERG, District Judge.
On June 6, 1991, Magistrate Judge Lefkow issued a report and recommendation on the parties' cross-motions for summary judgment concluding that plaintiffs had prepared the 1979 personal income tax returns of seventeen investors, and that they had willfully understated the tax liability on each return in violation of 26 U.S.C. § 6694(b). Under § 6694(b), an income tax return preparer may be assessed...
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