McKAY, Senior Circuit Judge.
The appellants, Mr. and Mrs. Fisher, were assessed a twenty-five percent penalty for substantially underreporting their taxable income in 1983 and 1984. 26 U.S.C. § 6661(a). (The Fishers had previously reached an agreement with the IRS on the amount of the deficiency for those years.) On May 25, 1989, the Fishers sought a waiver of these penalties under 26 U.S.C. § 6661(c), which provides the Commissioner of the Internal Revenue...
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