What is the effect of section 6621 of the Civil Code of Civil Procedure when dealing with civil matters?

MultiRegion, United States of America

The following excerpt is from DeMartino v. C.I.R., 862 F.2d 400 (2nd Cir. 1988):

1 This decision was summarily affirmed as to DeMartino's partner in McDonnell v. Commissioner, 862 F.2d 308 (3d Cir.1988).

2 Section 6621 provides that:

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