ORDER
SUSAN C. BUCKLEW, District Judge.
This cause comes before the Court on Plaintiff Natalie Swaney's Motion for Summary Judgment (Doc. No. 26). The Government has filed a response in opposition (Doc. No. 27). At issue is a series of penalties that the Internal Revenue Service ("IRS") levied against Swaney pursuant to 26 U.S.C. § 6701. For the reasons stated herein, Swaney's Motion for Summary Judgment is denied.
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