JUDGMENT
PER CURIAM.
This Cause having been heard and considered, it is Ordered and Adjudged:
AFFIRMED. See Fed. Cir. R. 36.
JADE TRADING, LLC, by and through, Robert W. ERWIN and Laura Kavanaugh Ervin, on Behalf of Ervin Capital, LLC, Partners other than the Tax Matters Partner, Plaintiffs-Appellees, v. UNITED STATES, Defendant-Appellant
451 F. App'x 954
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