The following excerpt is from Miller v. C.I.R., 935 F.2d 274 (9th Cir. 1991):
We review the tax court's imposition of penalties under 26 U.S.C. Sec. 6673 for an abuse of discretion. See Grimes v. Commissioner, 806 F.2d 1451, 1454 (9th Cir.1986).
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