United States Court of Federal Claims June 22, 2007, Nos. 98-533T, 98-5330 to 98-5350 (Gingerich v. United States)

OPINION AND ORDER

LETTOW, Judge.

The ultimate question in these 22 consolidated tax cases is whether the Internal Revenue Service (“IRS”) waited too long after a settlement was entered concerning a partnership item to assess the plaintiffs with additional tax and attendant penalties and interest. To resolve this question, this court must determine when the item was settled.