The following excerpt is from Retirement Fund Trust of Plumbing v. Franchise Tax Bd., 909 F.2d 1266 (9th Cir. 1990):
32 Another court has found that similar penalties create uncertainty and potential hardship so that such procedures are not "plain" or "efficient." See National Carriers' Conference v. Heffernan, 440 F.Supp. 1280, 1283 (D.Conn.1977) (Heffernan I ).
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