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ANDANTECH L.L.C. v. C.I.R.

Nos. 02-1213 & 02-1215.

331 F.3d 972 (2003)

ANDANTECH L.L.C., et al., Appellants, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Appellee.

United States Court of Appeals, District of Columbia Circuit.

Decided June 17, 2003.

Attorney(s) appearing for the Case

Walter A. Pickhardt argued the cause for appellants. With him on the briefs were Myron L. Frans, Mark Alan Hager, and William K. Wilcox.

Robert W. Metzler, Attorney, U.S. Department of Justice, argued the cause for appellee. With him on the brief was Richard Farber, Attorney.

Before: SENTELLE, HENDERSON and GARLAND, Circuit Judges.

Opinion for the Court filed by Circuit Judge SENTELLE.

SENTELLE, Circuit Judge:

This case arises from a final decision of the Tax Court rejecting challenges brought by the petitioners to the Commissioner of Internal Revenue's final administrative adjustments to the partnership tax returns filed by Andantech, L.L.C. for short taxable years ending December 10, 1993 and December 31, 1993, and for the taxable year ending December 31, 1994. The court first held...

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