MEMORANDUM OPINION AND FINAL ORDER
SUSAN BRADEN, District Judge.
This case presents jurisdictional issues relevant to federal income tax refund cases concerning partnerships. These issues are familiar to the court and the United States Court of Appeals for the Federal Circuit. See, e.g., Keener v. United States, 76 Fed. Cl. 455 (2007) ("Keener I"), aff'd,
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