Court of Appeals for the Fifth Circuit February 20, 1986, 85-2020 (Betty Jean Capps v. Roscoe Eggers, Commissioner of Internal Revenue Service)

POLITZ, Circuit Judge:

Betty Jean Capps appeals a summary judgment dismissing her action in which she sought to enjoin collection of a penalty assessed under 26 U.S.C. § 6682. Finding her contentions on appeal to be totally devoid of merit and wholly frivolous we affirm the district court, grant the government’s motion for sanctions, Fed.R.App.P.