SEYMOUR, Circuit Judge.
The Commissioner of the Internal Revenue Service appeals a decision of the Tax Court granting summary judgment in favor of Salman Ranch, Ltd. ("Partnership"), holding that the IRS's administrative adjustments of the Partnership's 2001 and 2002 tax returns were barred by the three-year limitations period in I.R.C. § 6501(a). We have jurisdiction pursuant to I.R.C. § 7482(a)(1). Because we conclude the IRS's adjustments were timely...
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