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Case 1:21cv00913KCD Document 34 Filed 02/01/22 Page 1 of 8IN THE UNITED STATES COURT OF FEDERAL CLAIMS NOT FOR PUBLICATION ___ ) CAPSTONE ASSOCIATED SERVICES, LTD.,) by and through CAPSTONE HOLDINGS ) CORP., Tax Matters Partner, ) ) Plaintiff, ) No. 21913T ) v. ) Filed: February 1, 2022 ) THE UNITED STATES, ) ) Defendant. ) ___ ) MEMORANDUM OPINION AND ORDER On February 11, 2021, Plaintiff filed this action contesting provisions of a Notice of Final Partnership Administrative Adjustment (FPAA)
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