Opinion by Judge LETTS
LETTS, District Judge:
I. OVERVIEW
Neil T. Nordbrock's ("Nordbrock") failure to turn over requested tax returns or taxpayer information to the Internal Revenue Service ("IRS") resulted in an IRS assessment of $75,000 against Nordbrock and a lifetime injunction prohibiting him from preparing tax returns for others. Nordbrock now appeals from the district court's judgment for the Government on his claim for a refund of...
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