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To reflect our conclusions and holdings above, we shall
grant petitioners’ motion to dismiss for lack of jurisdiction as
to the accuracy-related penalties. We shall deny petitioners’
motion in all other regards. We have considered all of the
parties’ arguments, and all arguments not discussed herein have
been rejected as moot, irrelevant, or without merit.
An appropriate order
will be issued.
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Last modified: November 10, 2007