TINDER, Circuit Judge.
Almost thirty years ago, the appellant-taxpayers entered into partnerships which the IRS later determined engaged in little more than tax avoidance. The path by which this matter reached our court was convoluted, but our decision is straightforward. We affirm the district court's holdings that it lacked subject-matter jurisdiction over the taxpayers' claims that the IRS's assessments against them were untimely and improperly included penalty...
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