PER CURIAM:
The Internal Revenue Service challenges the district court's holding that James Carroll Teal did not owe penalties or associated interest arising out of his 1979 income tax year (1979). We REVERSE.
I.
In 1983, Teal filed an amended return for 1979, claiming that, because of a tax shelter, he was entitled to a refund of approximately $13,000. The IRS made the refund, but subsequently notified Teal (late 1985) that he was liable for it...
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