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BROUNTAS v. COMMISSIONER

Docket Nos. 8231-76, 8497-76, 8698-77, 6255-78.

74 T.C. 1062 (1980)

PAUL P. BROUNTAS AND LYNN T. BROUNTAS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT CRC CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 13, 1980.

Attorney(s) appearing for the Case

Thomas B. Rutter, for the petitioners.

Bernard B. Nelson, Richard A. Hartnig, Robert T. Hollohan, Paul F. Kugler, James F. Malloy, Michael K. Phalin, and Richard B. Weinstein, for the respondent.

SUPPLEMENTAL OPINION

HALL, Judge:

On December 26, 1979, we filed our original opinion (73 T.C. 491) in this case in which we made exhaustive findings of fact which we adopt for purposes of this supplemental opinion. However, the complex nature of the transactions which underlie this case warrants a brief recital of the facts pertinent to this supplemental opinion.

CRC...

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