MEMORANDUM OPINION AND ORDER
CASTILLO, District Judge.
In the fall of 2000, Plaintiffs Terry Olson, Denny L. Robinson, and Albert Simon sought the counsel of various lawyers, accountants, and bankers in selling their respective companies and minimizing their tax liability. The Internal Revenue Service ("IRS"), however, ultimately found the tax strategy recommended to and used by Plaintiffs to be illegal, and Plaintiffs ended up losing hundreds of...
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