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HENSON v. COMMISSIONER

Docket No. 31654-83.

55 T.C.M. 1143 (1988)

T.C. Memo. 1988-275

Kenneth M. Henson and Sue B. Henson v. Commissioner.

United States Tax Court.

Filed June 27, 1988.

Attorney(s) appearing for the Case

James C. Fleming, 127 Peachtree St. N.E., Atlanta, Ga. and Bryan B. Lavine, for the petitioners. Charles P. Hanfman, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WHITAKER, Judge:

This cause is before this Court on remand from the Court of Appeals for the Eleventh Circuit following appeal by petitioners from our Memorandum Findings of Fact and Opinion reported at T.C. Memo. 1986-303.1 In our original opinion we concluded that respondent had sustained his burden of proving, by clear and convincing evidence, that...

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