OPINION OF THE COURT
SMITH, Circuit Judge.
This case presents a question of our jurisdiction to review orders of the Tax Court under 26 U.S.C. § 7482(a)(1). Appellant New York Football Giants, Inc. (the "Giants") appeals from an order of the Tax Court dismissing its petition with respect to some, but not all, of the tax years at issue. The Tax Court determined that it lacked jurisdiction over the Giants' petition with respect to those years. The Tax...
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