WHYTE, District Judge.
This case concerns the interpretation of two sections of the Internal Revenue Code ("IRC"), I.R.C. § 6229(a) and I.R.C. § 6501. Appellant AD Global Fund, LLC ("AD Global") appeals from the judgment of the United States Court of Federal Claims. The Court of Federal Claims held that § 6229(a) provides an extension of time to the statute of limitations in § 6501 for assessing taxes on partnership items, not a separate statute...
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