ORDER FROM CHAMBERS
SINGLETON, Chief Judge.
I. INTRODUCTION
Plaintiffs, Robert Walthall, Dorothy Walthall, and Jerry Dennis bring this action against the United States, seeking declaratory and injunctive relief in the form of an order preventing the Government from upwardly adjusting their tax liability for certain tax years during the 1980's. The Government adjusted Plaintiffs' tax returns based upon the audits of three partnerships, Union Energy...
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