PER CURIAM.
The government appeals from the District Court's grant of summary judgment to Roberta Lamb in her tax action requesting the refund and abatement of penalties assessed against her under 26 U.S.C. §§ 6700 and 6701 (1988).
Lamb, who is a bookkeeper, and a number of her clients invested in "energy management systems" in 1983. Lamb prepared income tax returns and Applications...
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