WOLLMAN, Circuit Judge.
Randall and Karen Thompson (the Thompsons) appeal from the United States Tax Court's order dismissing their petition challenging a notice of deficiency issued by the Internal Revenue Service (IRS). We conclude that the Tax Court had jurisdiction over the Thompsons' petition, and thus we reverse.
In 2001, Randall Thompson (Thompson) formed RJT Investments X, LLC (RJT) and began acting as RJT's tax matters partner. Later that year, Thompson...
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