OPINION ON REMAND
BARRETT, Circuit Judge.
This case is before us on remand from the Supreme Court of the United States which vacated our prior judgment without prejudice to the plaintiff-appellants, Alfonzo and Vivian Dowell, to raise the issue of our appellate jurisdiction over the judgment of the United States Tax Court. The Dowells have appeared before this court in appeals related to the same disputed taxes on three prior occasions. See Dowell v....
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