ORDER
BILBY, District Judge.
The Plaintiff, a tax preparer, filed suit seeking return of civil penalties assessed against him by the Internal Revenue Service (IRS). Both parties now move for summary judgment. The Court finds that the Defendant is entitled to judgment as a matter of law, and herein grants the Defendant's motion and denies the Plaintiff's motion.
BACKGROUND
The Plaintiff is a Certified Public Accountant who prepared the tax...
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