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SZOPA v. U.S.

No. 05-4788.

460 F.3d 884 (2006)

Sophie A. SZOPA, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided August 21, 2006.

Attorney(s) appearing for the Case

Sophie A. Szopa (submitted), Tinley Park, IL, for plaintiff-appellant.

Judith A. Hagley, Department of Justice Tax Division, Appellate Section, Washington, DC, for defendant-appellee.

Before EASTERBROOK, WOOD, and SYKES, Circuit Judges.

EASTERBROOK, Circuit Judge.

Our first opinion, 453 F.3d 455 (7th Cir. 2006), not only affirmed the district court's decision but also concluded that the appeal is frivolous and granted the United States' motion for sanctions. We expressed skepticism, however, about the Tax Division's request to set the presumptive sanction in tax-protest cases at $8,000, which it says is $3,000 less than the average expense of handling frivolous appeals...

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