Court of Appeals for the Ninth Circuit March 12, 2009, No. 07-16355 (Kassel v. United States)

MEMORANDUM *

The appellant Kassel brought an action against the government seeking a refund of the penalty assessed against him for violation of Internal Revenue Code (“I.R.C.”) § 6700. Kassel sought either a refund of all money he paid towards a penalty the I.R.S. imposed upon him for violating I.R.C.