Per Curiam.
These cases are before us for the third time because the BTA has failed to follow our past instructions. This matter would have been quickly and simply resolved if the BTA had followed our instructions on the first remand.
In the first appeal filed with this court, three issues were considered. The first issue was whether the appeal relating to the 1988 funds was filed in a timely manner; we affirmed the BTA's dismissal because the appeal...
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