Alpha I, L.P. ex rel. Sands v. United States

ORDER

HEWITT, Chief Judge.

Before the court are the United States’ Motion to Set Remaining Issues for Trial (defendant’s Motion or Def.’s Mot.), filed May 26, 2009, and Plaintiffs’ Response in Opposition to United States’ Motion to Set Remaining Issues for Trial (plaintiffs’ Response or Pis.’ Resp.), filed June 26, 2009. In defendant’s Motion, defendant states:

To the extent that the penalty issue is not resolved through ... pleadings [on the impact of plaintiffs’ § 465 concessions on plaintiffs’ challenges to penalties imposed by Final Partnership Administrative Adjustments (FPAAs) issued by…