OPINION
BOGGS, Chief Judge.
Daniel and Winnie Greer claimed a number of tax benefits from a 1982 investment. The IRS subsequently disallowed the benefits and, in 2003, imposed penalties on the Greers for negligently underpaying their taxes. The Greers challenged, inter alia, the amount of those penalties in the Tax Court, arguing that they had made a remittance in 1995 that paid their tax liability and thus reduced their penalties. The Tax Court rejected...
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