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BORCHERS v. COMMISSIONER

Docket No. 3576-86.

95 T.C. 82 (1990)

RICHARD J. BORCHERS AND JANE E. BORCHERS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 19, 1990.

Attorney(s) appearing for the Case

Bernie H. Beaver, for the petitioners.

Gail K. Gibson, for the respondent.

OPINION

RAUM, Judge:

The Court of Appeals for the Eighth Circuit vacated our decision in this case and remanded the case for further proceedings. See Borchers v. Commissioner, T.C. Memo. 1988-349, vacated and remanded 889 F.2d 790 (8th Cir. 1989). We have reexamined the entire case, and have concluded that the decision should be in favor of respondent. Before undertaking...

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