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KIM v. U.S.

No. 12-5013.

707 F.3d 335 (2013)

Calvin Ki Sun KIM and Chun Cha Kim, Appellants v. UNITED STATES of America, et al., Appellees.

United States Court of Appeals, District of Columbia Circuit.

February 8, 2013.

Attorney(s) appearing for the Case

Calvin K. Kim and Chun C. Kim, pro se, were on the brief for appellants. Joseph P. Drennan entered an appearance.

Kathryn Keneally , Assistant Attorney General, U.S. Department of Justice, Ronald C. Machen, Jr. , U.S. Attorney, and Michael J. Haungs and Gretchen M. Wolfinger , Attorneys, were on the brief for appellees.

Opinion for the Court filed by Senior Circuit Judge WILLIAMS.

WILLIAMS, Senior Circuit Judge:

Since 2002, Calvin and Chun Kim on the one hand and the Internal Revenue Service on the other have been in regular correspondence regarding the Kims' alleged failure to file adequate tax returns between 1998 and 2002. This correspondence culminated in the Kims' filing suit in district court in September 2008. In a previous opinion, we discussed the factual and procedural background at length. See Kim v. United States,

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