Plaintiffs were delinquent in filing tax returns for the years 1997 through 2002 and finally filed them all in 2003, after which they received from the IRS a statement of their tax liability as they and their accountant had computed and reported it, penalties assessed for late filing and late payment, and interest. Plaintiffs then retained defendants to seek an abatement of the late filing and late payment penalties on the ground of plaintiff Brian Cohen's medical condition...
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