AMENDED DECISION1
SINGLETON, Chief Judge.
I. Jurisdiction
The Government appeals from a decision by the bankruptcy court which invalidated readjustment of the tax returns of John and Barbara Camacho ("Camachos") to reflect earlier adjustments to the returns of certain partnerships in which the Camachos were indirect partners. See 26 U.S.C. §§ 6221-6233 (providing for a single unified audit and...
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