LYNCH, Chief Judge.
Plaintiffs Jonathan and Carol Shafmaster, once a married couple and now divorced, appeal from the United States District Court for the District of New Hampshire's grant of summary judgment to the United States on the plaintiffs' claim for refund of a failure-to-pay penalty imposed on them by the Internal Revenue Service (IRS).
The Shafmasters argue that there was at least a dispute of material fact as to whether the IRS was equitably estopped...
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