MESKILL, Chief Judge:
Appellant John M. Capozzi appeals from a decision of the United States District Court for the District of Connecticut, Daly, J., granting summary judgment in favor of the United States. The court held that the five year limitations period contained in 28 U.S.C. § 2462 does not apply to the assessment of penalties under 26 U.S.C. § 6700 (hereinafter "IRC § 6700"). Capozzi does not contend that any genuine issue of material fact...
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