CYNTHIA HOLCOMB HALL, Circuit Judge:
Appellees (collectively, "Taxpayers") are all small businesses or professional corporations. Each had in place a qualified individual defined benefit ("IDB") pension plan for employees. In 1989, the Internal Revenue Service audited Taxpayers' IDB plans as part of the Service's so-called Small Plan Audit Program. The Small Plan Audit Program represented the Service's attempt to crack down on what it believed were abusive tax practices...
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