contends that defendant violated I.R.C. § 6694. It imposes a penalty upon a tax return preparer who prepares a tax return which understates liability due to either an unreasonable position, see I.R.C. § 6694(a), or willful or reckless conduct, see I.R.C. § 6694(b). As discussed in detail above, defendant has prepared tax returns for CMI customers based on positions for which there was no “realistic possibility of being sustained on the merits” (for disclosed positions), I.R.C. § 6694(a)(1), or which were frivolous (for undisclosed positions), I.R.C. § 6694(a)(3). These returns have been determined by the IRS to con (W.D.Pa.1991) (injunction under § 7402 justified where defendant tax return preparer inflated expenses and deductions on returns); Music Masters, 621 F.Supp. at 1057 (<HOLDING>). V. GOVERNMENT’S ENTITLEMENT TO INJUNCTIVE
holding that an injunction is an extraordinary remedy holding that injunction order simply setting out elements necessary for relief and failing to identify the injury from denial of the injunction was conclusory and void holding that plaintiffs were not entitled to a preliminary injunction holding that an injunction was necessary under  7402 due to defendants continuing representation to investors that the deductions and credits attributable to an abusive tax shelter plan were allowable holding that  1983 is not an exception to the state tax injunction act