United States Court of Federal Claims August 26, 2009, Nos. 06-407 T to 06-411 T, 06-810 T, 06-811 T (Alpha I, L.P. ex rel. Sands v. United States)

OPINION AND ORDER

HEWITT, Chief Judge.

I. Background

Plaintiff Alpha I, L.P. (Alpha I), by and through Robert Sands, a Notice Partner in Alpha I, filed a complaint against the United States on May 18, 2006, “petitioning for the readjustment of partnership items that were adjusted by the Internal Revenue Service [ (IRS) ] in a Notice of Final Partnership Administrative Adjustment [ (FPAA) ] issued