HUG, Circuit Judge:
John and Mary O'Neill ("taxpayers"), investors in a tax shelter partnership, Interservice Group Limited ("IGL"), filed an action in district court seeking a refund of the taxes they paid as a result of adjustments made by the Internal Revenue Service ("IRS") to IGL's partnership return. The district court entered summary judgment for the Government on the ground that under 26 U.S.C. § 7422(h) it lacked jurisdiction to entertain actions "brought...
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