OPINION AND ORDER
PANNER, District Judge.
Plaintiff Pacific Wallboard & Plaster failed to pay its federal employment taxes in 1998, 1999, and 2000. The IRS assessed penalties totaling about $129,000. As required by law, Plaintiff paid the penalties and back taxes, then brought this action against the United States to obtain a refund of the penalties. The government now moves for summary judgment. I grant the motion.
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