OPINION & ORDER
[Resolving Doc. No. 1]
JAMES S. GWIN, District Judge:
I. Introduction1
With this action, two large national banks dispute adjustments that the Internal Revenue Service ("IRS") made to partnership federal income tax returns for the 1999, 2000, 2001, 2002, and 2003 tax years. In those adjustments, the IRS found that the banks' partnership, the AWG Leasing Trust, mis-characterized a...
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